Anything to report?

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

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

Contact: ombudsmann@remove-this.mtu.de

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@remove-this.mtu.de

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 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 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

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 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 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 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

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