Compliance
We set ourselves ambitious goals, act responsibly, keep our word and follow the rules.
Compliance is our shared responsibility. Each employee contributes personally to compliance with the rules and promotes integrity through their commitment, in order to ensure ethical behavior in all areas of the company.
Managers have a special responsibility in this regard. Ensuring compliance with internal and external requirements is a central task of all RUAG managers. The attitude and behavior of superiors, as well as the measures they take, set the tone for behavior and culture at RUAG.
COMPLIANCE MANAGEMENT SYSTEM (CMS)
The Group's Compliance Management System (CMS) provides an overarching framework for actively identifying, assessing, mitigating and monitoring compliance risks and ensuring compliance with compliance requirements within the Group. The Head of Compliance is responsible for designing and implementing the necessary measures to ensure the CMS.
The Audit and Risk Committee and the Board of Directors retain ultimate oversight of the compliance program. Regular compliance updates enable these bodies to assess the effectiveness of compliance initiatives and the measures implemented accordingly. This is done in consideration of the results of the reviews by the internal and external auditors to ensure that the necessary adjustments to the programs are implemented. The shareholder is informed about compliance issues in quarterly reports and discussions and in the annual report.
Our compliance management system (CMS) is based on the principles of prevention, detection and response. Through early identification of compliance risks and practical training, as well as clear guidelines, misconduct is preventively mitigated. Internal investigations and a whistleblower system help to identify violations, while regular controls ensure compliance with regulations. Reports are treated confidentially and in accordance with the group's guidelines, with sanctions imposed for violations and audits conducted to improve processes.
The effectiveness of the compliance program is reviewed and adjusted as needed by means of regular training, employee surveys, audits, and internal and external audits.
Code of Conduct
The Code of Conduct is our binding set of rules that applies to all employees and sets out clear values and principles. It commits us to legally compliant behavior, both internally and in our dealings with customers, business partners, suppliers, society, politics, authorities and our shareholder, the Swiss Confederation. Behavior is only permissible if it complies with applicable laws and is compatible with our Code of Conduct.
The Code of Conduct in its currently valid version forms an integral part of every employment contract and is available in all corporate languages.
Code of Conduct for Business Partners
As a corporate group operating internationally, RUAG is committed to conducting its business in an ethical, legally correct and socially responsible manner. RUAG also expects its business partners – including customers, suppliers and service providers – to act in an irreproachable manner. To substantiate these expectations, RUAG has established certain minimum standards that are made known to its business partners. The Code of Conduct for Business Partners is part of the contracts with third parties and is binding. The document is available in the download area.
Policies and processes
All binding rules of conduct and processes are embodied in appropriate guidelines (policies, regulations, supporting documents) for the group. The formal requirements for the corresponding guidelines are set out and documented in writing. Guidelines for the group are regularly and formally reviewed and must not be contradictory or mutually exclusive.
Anti-bribery and anti-corruption
RUAG has a zero-tolerance approach to corruption and strictly rejects any form of bribery or other corrupt behavior.
Gifts and donations may only be given, received or offered within the framework of customary business hospitality and in accordance with RUAG rules. RUAG does not make donations to parties and it is forbidden to use donations to influence decisions. Excessive or inappropriate donations are not permitted. In particular, payments to accelerate the performance of official duties without discretion (e.g. facilitation payments) are prohibited.
We take appropriate precautions to implement our commitment to prevent corruption. These include, among other things, the personal commitment of each employee and our contractual partners to consistently refrain from any kind of bribery. We also train employees and provide them with advice and support as needed. If there are relevant, specific grounds for suspicion, we are prepared to forgo a business opportunity.
Avoiding conflicts of interest
Conflicts of interest not only pose a risk to RUAG as a company, but also a potential risk of corruption. Since employees also have private interests and relationships, RUAG has introduced a guideline that regulates how to deal with actual, potential or suspected conflicts of interest in order to avoid negative consequences for both employees and the company.
In addition to describing specific, potential conflicts of interest, the regulation also includes a uniform process for reviewing potential conflicts of interest and monitoring those that have been identified.
All employees receive training on the specific risks related to conflicts of interest as part of the compliance training program.
Dealing with third parties
There is an increased risk of corruption when working with third parties. It is therefore important to carry out a risk-based compliance check in advance. This is done with the support of a web-based application that includes automatic compliance checks. External audits by independent experts may also be carried out within the limits of the applicable legislation. This due diligence process is repeated regularly, but at least every three years if the contractual relationship remains unchanged.
RUAG works exclusively with selected and audited agents and brokers and has implemented a specific set of rules for dealing with agents, consultants and resellers. Business partners are required to comply with the RUAG Code of Conduct. The procurement department of the respective group companies is involved in the process of accepting new supplier relationships and is responsible for implementing processes and controls. Third parties are required to submit quarterly activity reports and to provide information on any contact between a third party and a business partner.
By regularly reviewing our contractual partners, we ensure that these provisions are an integral part of the contractual relationship (supplier-subcontractor) along the entire supply chain.
Training
RUAG places a high priority on all employees being familiar with and actively implementing the company's internal requirements. The relevant requirements are provided in a comprehensible form and communicated through targeted training.
Training is deliberately provided according to hierarchy levels, tasks and the associated risks. It is carried out by addressing employees, managers and the Board of Directors personally. In addition, where appropriate, additional training is offered to all employees via e-learning modules and digital platforms.
The effectiveness and content of the training and communication program are continuously reviewed and updated through feedback from workshops, one-on-one meetings, employee surveys, e-learning statistics, internal and external audits, and case evaluations.
Trade Compliance
RUAG, as a company owned by the Swiss Confederation, is aware of its responsibility as a provider of military applications.
We comply with the local regulations of the countries in which we operate and, regardless of the location of the business units, with Swiss export control regulations, in particular the Federal Act on War Material, the Federal Act on the Control of Specific Military Goods, the Federal Act on the Implementation of International Sanctions, the Embargo Act, the Ordinance on the Export and Brokering of Goods for Internet and Mobile Phone Monitoring and the Federal Act on Private Security Services Provided Abroad.
Data protection
Trust is our foundation
In an increasingly digital world, data protection is of central importance. RUAG takes the protection of personal data very seriously. Data protection concerns not only the company management, but each and every one of us – whether as an employee, customer or partner. RUAG is aware that the handling of personal data requires trust, and this trust is the basis of our relationships.
Data protection is an essential part of the compliance remit, and we treat it as a top priority. To ensure effective data protection management, RUAG has data protection coordinators working in their corresponding areas. In addition, all employees receive regular training according to their needs to continuously promote awareness and skills in data protection. Furthermore, a data protection advisor has been appointed to support data protection in all matters.
For RUAG, it is essential that personal data is protected with the utmost care. Only by handling information responsibly can a secure environment be created.
REPORTING CHANNELS & WHISTLEBLOWING
In line with our values, all employees are encouraged to report information about violations of the Code of Conduct or applicable law immediately. We are committed to an active speak-up culture.
Employees have the option of initially reporting potential compliance violations to their supervisor, HR manager or Compliance. Our "Integrity Line" allows employees and third parties to report suspected or observed irregularities and violations, anonymously if they so choose. Reports are viewed and processed only by designated RUAG specialists from the Compliance team.
Employees who report known or suspected violations in good faith are protected from reprisals. Any kind of reprisal against employees who report violations in accordance with these principles is a clear and serious violation of this Code of Conduct and will be sanctioned appropriately.
RUAG takes reports of potential compliance violations very seriously and follows up on every report, especially those concerning contracted service providers, suppliers, agents and their suppliers. Compliance violations by contractual partners will not be tolerated and may result in the immediate termination of the business relationship.
Downloads
Would you like to find out more? We have a range of information available to download here.
Topics for further reading
Board of Directors
Management
