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Safe and confidential

We do not tolerate any conduct that violates laws or regulations. We respond immediately to all leads reported and investigate these thoroughly. Any detected violations will be subject to disciplinary action. Should a lead turn out to reveal that there has simply been a misunderstanding, it may still help us improve our work processes and business relationships.

Integrity begins when people do the right thing of their own volition—especially when others are not doing so. So have the courage to contact us! At MTU, we have set up channels for reporting unlawful conduct. These are open to MTU employees but also to external parties to report any suspicious circumstances or instances of abuse.  

We wish to make it clear that whistleblowers acting in good faith shall not be penalized or disadvantaged by the company in any way, even if their accusation turns out to be baseless. We are grateful for the leads you report, not least because this demonstrates your interest in protecting our company and tackling possible abuses.

The identity of each whistleblower and the information they provide are treated as confidential. Reports submitted will not be traced back to their source and the reporters themselves are not registered automatically.

Reporting channels

Ways of submitting your report to us

iTrust

We established iTrust, a web-based whistleblower system, as a key resource for reporting potential legal infringements or misconduct. It is available to our own employees and to those of our suppliers and business partners as well as to other third parties at any time as a channel for reporting—anonymously if preferred—confidential leads for potential violations of rules. Here we expressly encourage whistleblowers to take advantage of the option available in iTrust of setting up an electronic mailbox to manage communication with the Compliance Officer.

iTrust

Ombudsperson

If you suspect that MTU or an MTU employee could be engaged in misconduct, you can — anonymously if preferred — contact the Ombudsperson.

Contact: ombudsmann@mtu.de

Direct communication

Naturally, there are also direct communication channels open for reporting violations of rules to the Compliance Officer, management, HR and employee representatives.

Contact for the Compliance Office: compliance@mtu.de

Site-specific reporting channels

MTU has also established site-specific reporting channels. For example, in compliance with statutory regulations such as the AGG in Germany, trained personnel at each site are identified as the contact points for complaints regarding discrimination. For cases of sexual harassment, female employees can go to a female contact person.

At MTU Maintenance Canada, employees can file a formal complaint with human resources management in cases of discrimination. They also have the option of going beyond the company to make a formal complaint to the BC Human Rights Tribunal.

At MTU Aero Engines Polska, this function is carried out by a person elected by the employees.

How does the process work?

Step 1: Responsibilities

At MTU, the Compliance Officer is generally responsible for processing leads relating to unlawful conduct submitted via iTrust or other channels.At MTU, the Compliance Officer is generally responsible for processing leads relating to unlawful conduct submitted via iTrust or other channels.

Step 2: Report submission and confirmation of receipt

Upon submitting a lead, the whistleblower receives confirmation of receipt. They may by asked to submit additional essential and relevant information and documents.

The identity of the whistleblower and the content of the report are treated in strictest confidence. Data submitted will be forwarded to other entities within or outside MTU only where this is necessary to investigate and resolve the report, or to define follow-up measures.

Step 3: Risk-based initial assessment

A risk-based initial assessment of the potential rules breach is carried out.

Step 4: Investigation & resolution

Depending on the type and severity of the accusation, the Compliance Officer initiates and/or coordinates appropriate measures. This starts with establishing the facts surrounding the accusation and continues with the coordination of the suitable and appropriate countermeasures required. It may also be necessary to involve other individuals and departments (e.g. data protection officers, internal audit, corporate security) on a confidential basis, or to forward the report to the appropriate bodies (e.g. investigative authorities, contacts at suppliers).

The Compliance Officer has unrestricted rights of information, investigation and inspection, and coordinates the inquiry while maintaining confidentiality and neutrality. Parties accused are presumed innocent until proven guilty. The inquiry takes into account both incriminating and exculpatory evidence.

Step 5: Consequences resulting from inquiry findings

Once the inquiry is complete, suitable and appropriate follow-up measures are defined should the inquiry have determined that the accusation is founded.

Depending on the severity of the offence, unlawful conduct by MTU employees can result in labor law measures (e.g. warning, dismissal, demand for restitution, reimbursement and/or compensation) being taken. Measures taken against suppliers or business partners are in accordance with the applicable laws and contractual agreements.

In the case of criminal offences, MTU reserves the right to file charges.

Step 6: Feedback to the whistleblower

The whistleblower is informed about the results of the inquiry. Personal data gathered is deleted as soon as the applicable retention period has expired.

What kind of reports help MTU?

Bribery & corruption

Corruption is the abuse of public office, a position in industry or a political mandate (powerful position) typically in pursuit of improper personal gain at the expense of the general public or a company.

One form of corruption is bribery.

Bribery includes the improper use of contributions such as gifts, entertainment and hospitality in exchange for improper advantage. Corruption can take active forms (e.g. claiming, offering and promising improper advantage), and passive forms (e.g. accepting improper advantage).

Examples:

  • Accepting a gift from a supplier in exchange for preferential treatment in competitive tender processes
  • Making illicit payments to a government official (either directly or through a third party) in exchange for benefits or preferential treatment

Theft

Theft means the unauthorized seizure or appropriation of property (objects or money) belonging to someone else, either out of self-interest or with the intention of passing it on to others.

Examples:

  • Theft of goods from a warehouse
  • Theft of tools or office supplies

Capital market offences / insider trading

Capital market offences include attempts to influence market pricing by supplying false or misleading information about the supply or demand of a financial instrument. The result is a price level that would not have occurred had the supply and demand relationship not been tampered with.
Insider trading is used to describe instances in which a person (insider) uses information not available to the public at large (insider information) to their advantage when making market transactions. Insider information includes details about an upcoming takeover, liquidity problems, the award of a major contract, the purchase or sale of larger share parcels, and unpublished research studies conducted by listed companies.

Examples:

  • Sending a mass of e-mails advertising a particular stock with the intention of driving up the price
  • Making use of information not available to the public at large in the purchase or sale of company stock; the unauthorized forwarding of insider information to third parties

Violations of antitrust/competition law

These are violations of statutory regulations designed to safeguard and preserve effective competition in the market by protecting trade from improper practices such as anti-competition agreements between competitors and the formation of monopolies.

Examples:

  • Unauthorized sharing and discussion of competition-relevant information between MTU and a competitor

Human rights violations / bullying / harassment

Human rights are subjective rights defined and justified by human dignity and to which all people are equally entitled by virtue of their personhood. Human rights violations refer to when a person is persecuted, threatened or discriminated against on the basis of their religion, ethnicity, political affiliation or sexual orientation, or when the environment of a local population is destroyed. For MTU, this category also includes violations of environmental due diligence legislation that have a potentially negative impact on human rights.

Within the company, MTU considers this category to include unsolicited and unwanted verbal or physical advances as well as harassment, injury or similar designed to drive someone out of the company or torment them into leaving.

Examples:

  • Child labor
  • Forced labor
  • Discrimination
  • Sexual harassment
  • Salacious comments
  • Humiliation
  • Marginalization

Conflicts of interest

Conflicts of interest generally arise when a person is faced with several, different interests that conflict with each other, or when a particular interest or interests could corrupt that person’s motivation or decision-making. If an employee has, for instance, a personal or especially an economic or private interest that could potentially influence or impair their professional commitments and responsibilities, that employee is said to have a conflict of interest.

Example:

  • An external company to which an MTU employee has a relationship (e.g. through owning shares) is given preferential treatment when bidding for a contract

Fraud and violations connected with financial reporting

Fraud is the term given to unlawful or criminal conduct designed to deceive others in order to obtain an unlawful personal or financial advantage. Fraud includes the deliberate distortion of facts for other people in order to encourage them to grant advantages to the fraudulent individual.

Violations connected to financial reporting include any and all activities that breach the generally accepted accounting principles and thus also the standards or practices of corporate financial reporting. Violations connected to financial reporting may also include invalid reporting or item booking that leads to misrepresentation in the company’s account books and records.

Example:

  • Misrepresentation of the details of a transaction in MTU’s finance system and reporting procedures

Violations of international trade regulations (export control or customs)

This category includes serious infringements of statutory regulations with respect to national, EU or U.S. (re-)export control law and customs law as well as violations of MTU regulations and intentional circumvention of the international trade department.

Examples:

  • Evasive business practices or unauthorized trading or intermediary activities
  • Intentional declaration of inaccurate goods value, tariff classifications or goods descriptions

Other serious regulatory or statutory violations

This category relates to other major violations of laws or MTU regulations. These include criminal acts, offences and breaches of contract that expose MTU to the risk of significant financial loss or serious damage to its reputation.

For instance, serious violations of the laws governing:

  • Data protection
  • Espionage
  • Sabotage
  • Product conformity

In addition, violations of workplace health and safety policy—such as guidelines put in place to protect employees—could constitute a criminal offence and have serious consequences for MTU. Violations of environmental protection laws and regulations can pose a significant threat to MTU. This includes environmental contamination and improper handling of hazardous waste.

How iTrust works

Read more about iTrust

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