Compliance

A self-evident part of management and corporate culture

The ethical basis for compliance at Zeppelin is the conviction that social responsibility, observance of the law, and conduct with integrity are essential for long-term business success. Compliance with legal requirements, official regulations, and internal corporate guidelines is a key part of Zeppelin’s management and corporate culture.

As part of its compliance management system, the Zeppelin Group has set up various processes to prevent and at least detect compliance violations and to create remedial action. Internal rules and guidelines provide management and staff with clear guidance and explain the ethical and legal motives behind the compliance program.

The Zeppelin Code of Conduct for Business Ethics and Compliance describes these fundamental principles of business conduct – within the Group, but also vis-à-vis our partners and the public at large. In connection with Zeppelin’s partners, i.e. suppliers, service providers, and subcontractors, Zeppelin has set out its expectations in the Code of Conduct for Suppliers and at the same time defined them as the basis for cooperation. Integrity is an irrefutable corporate value in all business activities and relationships.

Any form of corruption, bribery, extortion and embezzlement in business transactions or violation of export control regulations and sanctions are rejected. The scope of compliance requirements and desirable conduct in order to meet them are explained to all employees through information and training. These address not only rules that must be complied with, but also the early identification of transgressions and the submission of information in order to eliminate possible abuses.

The internal compliance organization ensures that the compliance management system is coordinated throughout the Group and that contact persons, who employees can turn to in confidence, are available within all companies. A separate e-mail address for questions and information relating to compliance matters is also available.

There is also an online whistleblower system that can be used to submit reports in all languages relevant to the Zeppelin Group and its business partners. The system offers the option of contacting the Zeppelin Group anonymously and confidentially. Zeppelin works with an external partner to provide this reporting system; our partner continually updates the system to reflect the laws and requirements of worldwide whistleblower reporting. The system is compliant with the General Data Protection Regulation, and is audited and certified according to ISO 27001.

External ombudsmen are appointed in selected countries in which Zeppelin operates. They make it possible to confidentially contact a neutral and qualified person of trust with any questions relating to compliance and, in particular, relating to compliance with legal requirements and internal guidelines. In addition, it is possible to make contact directly via the responsible Chief Compliance Officer (CCO) and the employees of the Compliance Organization. All contact channels are available to employees, business partners, and other third parties on an equal footing.

Progress in compliance

One objective in the area of compliance is to maintain a corporate culture in which compliance with legal and ethical obligations is a matter of course. Compliance transgressions are to be largely avoided through targeted information provision and regular training of employees and managers.

All reports were checked immediately, confirmed compliance violations were dealt with and essentially corrected by the Compliance organization in cooperation with the affected specialist units, i.e. Internal Audit and Legal.2 Violations from 2022 that have not yet been remedied are still being dealt with. The majority of violations discovered at Zeppelin were incidents in the areas of fraud and export control law. They were either reported via notifications or discovered due to existing internal controls of the Compliance Management System. All cases occurred within the Zeppelin Group and did not involve any third parties. They did not have a negative impact on the economic stability of the company or lead to any significant need for adjustment with regard to processes or rules. In recent years, there have been no known cases of non-compliance with laws resulting in fines, penalties or forfeiture.3 Over the next few years, the aim is to create the best possible transparency in compliance reporting and to further avoid compliance violations.

A corresponding corporate culture of compliance can only be nurtured if all employees have the necessary knowledge and are able to develop the necessary and appropriate awareness of compliance. Zeppelin regularly informs its employees about compliance challenges and risks and demonstrates desired conduct in line with Zeppelin’s values through training courses. The aim is for the proportion of employees with valid compliance training to be greater than 80% over a rolling period of four years.

The compliance training concept at Zeppelin consists of workshops for Management and employees in which the challenges of compliance in terms of management responsibility and the understanding of values within the Zeppelin corporate culture are conveyed. Supplementary e-learning programs provide basic compliance knowledge and material statements of the Zeppelin Code of Conduct for Business Ethics and Compliance for all employees (basic training) as well as basic principles of corruption prevention for particularly exposed employees, e.g. those working in purchasing and sales roles.

Since 2021, all employees have had to complete the “Compliance Basics” training module. This module explains the topics of correct conduct, corruption prevention, antitrust law and other topics. It is a mandatory program component for all employees. From 2023, another module on “Dealing with business partners” will be available. The module focuses on corruption prevention for those working in purchasing, sales & marketing, prevention of money laundering and terrorist financing, export controls and dealing with embargoes, and is aimed at selected exposed employee groups.

Since the introduction of the new e-learning system, Zeppelin has been continuously working on further improving the participation rate and implementing suitable measures to achieve this; these will be presented in the next section.

Measures implemented in 2022 from Compliance

The aim of the Compliance organization is to make the newly introduced e-learning module available to as many employees as possible as a simple introduction to compliance. Therefore, it was important to offer a learning program with a wide range of languages. Both e-learning modules are available in the company languages of German, English, French, Italian, Polish, Portuguese, Russian, Slovak, Czech, and Ukrainian. The module has also been available in Mandarin Chinese since 2022. The training modules are also available in a responsive design and can therefore be taken on all mobile devices.