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 detect compliance violations and to take 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 partners and the public at large. In connection with Zeppelin’s partners, i.e. suppliers, service providers, and subcontractors, the Group 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 risks and 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 has also been set up.
There is also an online whistleblower system, Trustline, 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 or the relevant Zeppelin company 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
- Ensure a high training rate in the area of compliance: over 90%1
A compliance culture in which compliance with legal and ethical obligations is a matter of course can only develop with the necessary knowledge and awareness of compliance. Through regular training, the company informs its employees and managers about Zeppelin’s values, the application of which makes an important contribution to working together with integrity. The aim is for the proportion of employees with valid compliance training to be greater than 90% over a rolling period of four years.
The compliance training concept at Zeppelin consists of workshops for management and employees, which teach the challenges of compliance in management responsibility and the understanding of values within the Zeppelin corporate culture. 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.
| Total number and participation rate | Unit | 2021 | 2022 | 2023 |
|---|---|---|---|---|
| Overall participation | Number | 7,977 | 8,285 | 9,860 |
| of whom managers2 | Number | 40 | 58 | 903 |
| Total participation rate | % | 75.6 | 80.5 | 96.8 |
| 2 In the 2021 and 2022 reporting years, the data only included management (senior management level); from the 2023 reporting year, the indicator has included all management levels of the Group. | ||||
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. This module is mandatory. Starting in 2024, the “Dealing with business partners” module will also be available and will focus on corruption prevention for those working in purchasing, sales & marketing, prevention of money laundering and terrorist financing, export controls and dealing with embargoes. The module is aimed at selected exposed employee groups.
| Transgressions and resolution rate | Unit | 2021 | 2022 | 2023 |
|---|---|---|---|---|
| Reported transgressions | Number | 23 | 25 | 30 |
| of which confirmed transgressions | Number | 11 | 15 | 9 |
| of which resolved transgressions | Number | 6 | 14 | 9 |
| Compliance resolution rate | % | 55 | 93 | 100 |
| Fines / corruption cases | Unit | 2021 | 2022 | 2023 |
|---|---|---|---|---|
| Amount of fines, penalties and forfeitures imposed by final judgment | Euro | 0 | 0 | 0 |
| Corruption cases | Number | 0 | 0 | 0 |
| Total number of legal proceedings due to anti-competitive conduct and transgressions of antitrust and monopoly law | Number | 0 | 0 | 0 |
All reports received in the 2023 fiscal year were promptly checked, and confirmed compliance violations were processed and substantially corrected by the Compliance organization in cooperation with the relevant departments, in particular the Audit department and the Legal department.3 Violations from 2023 that have not yet been remedied are still being processed. 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. In recent years, there have been no known cases of non-compliance with laws resulting in fines, penalties or forfeiture.4
Measures in 2023
The goal of the Compliance organization is to provide as many employees as possible with an easy introduction to the topic of compliance through the training program (e-learning). Therefore, it was important to offer a learning program with a wide range of languages. Both e-learning modules are available in German, English, French, Italian, Polish, Portuguese, Russian, Slovak, Czech, Mandarin and Ukrainian. The training modules have been created with a responsive design and can therefore be taken on all mobile devices. The introduction of a Learning Management System at Zeppelin has made it possible to create a breakdown of the training courses by region and to prepare a corresponding report. Based on this information, targeted communication is planned to increase the participation rate and achieve the defined targets.
1 Target adjustment compared with previous year: Increased compliance training rate from over 80% to over 90%
3 Unresolved cases were still in resolution at the time of reporting.
4 Forfeiture is a measure for asset recovery provided for in criminal law.