Metrics and targets
G1-4 – Incidents of corruption or bribery
In fiscal year 2024 / 2025, there were no incidents of corruption or bribery that resulted in the company being prosecuted or receiving a fine.
G1-5 – Political influence and lobbying activities
At thyssenkrupp AG, political lobbying is performed by the Corporate Function Communications, which reports directly to the CEO of thyssenkrupp AG. Therefore, the responsibility for political lobbying is assigned to the CEO directorate of thyssenkrupp AG.
The main principles and rules for political lobbying are contained in our Code of Conduct. In addition, thyssenkrupp has a group policy governing all activities relating to our political activities and points of contact. In particular, this relates to the following activities:
Political activities and lobbying
Individual membership (not private) in industry association boards, working groups and initiatives relating to political topics for thyssenkrupp, such as professional associations
Drafting of position papers in the aforementioned associations, working groups and initiatives
Contact and meetings with politicians, decision-makers and public officials, visits by and meetings with these persons
Participation in business delegations during official government visits
Publication of politically relevant content
This group policy also states that political activities should be coordinated, open and transparent and that regulatory and ethical standards must be complied with. In addition, the group policy describes the fundamental goal of political activities. Through these and its lobbying work, thyssenkrupp seeks the inclusion of its interests in the policy-making process by political representatives so that it can achieve its own business ambitions. The group policy currently does not explicitly address the impacts and opportunities identified in the double materiality assessment for the topic area of “political influence and lobbying activities.”
In addition, thyssenkrupp has committed in its Code of Conduct to not make any direct or indirect financial payments and contributions in kind to political parties, to organizations affiliated with or resembling political parties, or to politicians or candidates for elected office. The Code of Conduct applies to all thyssenkrupp companies, employees, managers and members of the Executive Board and management teams. Our goal is to ensure that thyssenkrupp’s political lobbying complies with the principles of integrity and professionalism and that the company does not exert undue influence on policy and legislation. Moreover, no Executive Board or Supervisory Board member of thyssenkrupp AG held a comparable role in a public administration or regulatory authority in the two years prior to their appointment to their respective functions.
thyssenkrupp AG is included in the German Parliament lobby register (register number: R001468) and the European Union Transparency Register (register number: 991340152782-87). In addition, certain thyssenkrupp subsidiaries have separate entries in the German and European registers:
thyssenkrupp Decarbon Technologies GmbH (527995398085-85)
thyssenkrupp Marine Systems GmbH (R003238)
thyssenkrupp nucera AG & Co. KGaA (R003302 and 326446553312-61)
thyssenkrupp Polysius GmbH (R006215)
thyssenkrupp Steel Europe AG (R001828 and 456211534646-58)
thyssenkrupp Uhde GmbH (R006245)
Focus of political lobbying
Through its political lobbying, thyssenkrupp seeks to be a partner and advisor to the government and to work with the government to facilitate the green transformation of industry, strengthen its competitiveness and drive other key industry policy matters such as the strategic autonomy of Germany and Europe. We aim to actively shape the economic policy framework. To achieve this, it is essential to maintain an ongoing and regular dialog with political stakeholders. thyssenkrupp is focusing on the following topics:
Green transformation – To ensure the success of the green transformation, we believe it is necessary to promote technologies and processes as broadly as possible. This applies especially to ramping up the hydrogen economy. Once this has been completed, the comprehensive decarbonization of industrial processes and energy supply will be possible. En route to a green hydrogen economy, thyssenkrupp is committed to using blue hydrogen during the transition phase. From thyssenkrupp’s perspective, it should be possible to use technologies such as carbon capture and storage (CCS) so that industrial processes can be decarbonized as soon as possible. thyssenkrupp is also committed to creating green lead markets in which the use of climate-friendly basic materials – i.e., materials whose production is associated with lower carbon emissions – is incentivized by suitable political framework conditions.
Secure energy supply – Securing stable and competitive energy prices in the long term for Germany and Europe is of crucial importance for thyssenkrupp. This applies both to the price of electricity, which will become increasingly important with the shift to electrification, and to the price of green hydrogen, which is necessary for the green transformation.
Trade defense measures – In recent years, the number of low-price imports from non-EU countries has increased dramatically, especially in the steel industry. That is why thyssenkrupp advocates for effective trade defense measures. Greater use must be made of the scope provided by existing WTO and EU legislation, and new instruments (tariffs) must be established to provide protection against low-price imports from countries with overcapacities. In addition, thyssenkrupp supports effective carbon leakage protection and, for example, is arguing for changes to the Carbon Border Adjustment Mechanism (CBAM) such as an extension of its application to include processed steel-intensive products.
Strategic autonomy – In times of growing geopolitical tensions, it is increasingly important to keep basic technical skills and production capacities in Europe. From thyssenkrupp’s perspective, the strategically important industries include plant engineering, naval shipbuilding and steel production. If these competencies are kept in Germany and Europe, it will be easier to protect value chains. thyssenkrupp advocates for resilient and diversified supply chains, the support of a strong European industry base and the retention of technical and industrial skills (Buy European).
Measures in connection with political lobbying
The green transformation of our economy is one of the biggest challenges and, at the same time, one of the biggest opportunities for Germany and Europe. Coordinated solutions are needed to ensure that Germany and Europe remain attractive and competitive industrial locations. Against this backdrop, thyssenkrupp’s business conduct is shaped by policy choices and regulation. As thyssenkrupp’s steel production – together with the cement industry – is associated with a large proportion of emissions, the most important and effective decarbonization levers focus mainly, if not exclusively, on the political frameworks relating to the environmental transformation of steel production. For this reason, most of thyssenkrupp’s political lobbying – in respect of the potential positive impacts and opportunities of direct dialog with policy makers and the shaping of the regulatory environment – is conducted by Steel Europe.
Against this backdrop, thyssenkrupp participates in regular dialog with various stakeholder groups at the regional, federal and EU levels, contributing recommendations on how to achieve the green transformation and sustain the long-term competitiveness of industry in Germany and Europe. In this connection, thyssenkrupp regularly addresses specific regulatory plans, especially those concerning climate change, energy and hydrogen, at national and European level. The thyssenkrupp companies included in the lobby register regularly publish an overview of these regulatory plans. Also listed and described are memberships of associations and the reported financial spending (for example, personnel, infrastructure and representation costs) for political lobbying. In the coming fiscal year, spending is expected to be similar to that in 2024 / 2025.
G1-6 – Payment practices
The general conditions of procurement applied by thyssenkrupp companies also include standard payment terms. The term “standard payment terms” refers to the period for payment contained therein; this is defined by the individual companies. No distinction is made on the basis of supplier category. As a rule, the period for payment is between 60 and 90 days. In deviation from this, it is only 30 days at some European sites and, in exceptional cases, as much as 180 days at some sites of the Decarbon Technologies and Automotive Technology segments in the Far East. Some smaller group companies do not apply standard payment terms but reach individual agreements with their suppliers regarding payment for products or services.
We determine the datapoints that we are statutorily required to report by assessing the available information from the individual ERP systems used by the group’s legally independent entities. Around 96% of thyssenkrupp’s spending is covered by the reported metric; ERP systems offered no possibility for assessing the remaining 4%. We have not found any indication that the spending that could not be included in the assessment deviates systematically from the spending that is included. The remaining 4% is therefore estimated on the basis of the figure for the 96%.
In the reporting year, the average time between the start of the period for payment and actual payment was 35 days; 75% of payments were made in line with the standard payment terms. In the case of individual agreements on payment terms longer than the standard payment terms, the payment transaction was assessed as not complying with the standard payment terms – even if payment was made in line with the respective individual agreement. Late payments may be caused by the process when slight delays result from weekly payment runs.
As of the reporting date on September 30, 2025, no legal proceedings by suppliers for late payment were pending.