Team size: 20

What are the most significant cases, projects, or transactions that you and your legal team have recently been involved in?

Managing several M&A processes, including the establishment of clean teams and the implementation of strict gun-jumping safeguards.

Investigating a number of high-stakes whistleblowing reports.

Implementing purchasing cooperation arrangements with competitors, while ensuring compliance with competition law requirements and achieving efficiencies and economies of scale.

Strengthening compliance with trade sanctions requirements, including enhanced shareholder due diligence and more rigorous risk-based screening in jurisdictions commonly associated with sanctions circumvention.

How do you approach managing legal aspects during periods of instability or crisis to ensure the organisation’s resilience?

Periods of crisis require particular focus because the strength of the compliance management system and the compliance department prove themselves in times of crisis. It is exactly when the management thinks (and sometimes says) that “we now have a lot of other problems than compliance” when compliance should get to work. However, it is important to know that compliance offers also chances, supports management and co-determines on the level of risk aversion in each situation. Following structures and processes in times of crisis gives security that the company will master the scrutiny that comes after the crisis.

Based on your experiences in the past year, are there any trends in the legal or business world that you are keeping an eye on that you think other in-house lawyers should be mindful of?

AI is changing the way we work and the way our companies work. AI compliance has become part of our core compliance topics. Similarly to data protection and IT security, which are included in the design of the structures, we are setting up also AI structures to be “AI compliant by design.” This means that all AI tools are registered, assessed based on their risk profile, approved by compliance and business and their developments are closely followed. It is important to make sure that we understand the ways we use AI and remain in charge of the AI processes and decision-making.

What do you think is the greatest innovation you have enacted in the past year?

Within the thyssenkrupp Group, all memberships in associations, as well as donations and sponsorships (including commercial sponsorships) need to be registered and approved in a dedicated tool. A positive compliance statement by the Legal & Compliance Team is required in all cases (with further requirements in cases of higher risks/amounts involved). Given the size of the group and the corresponding high number of memberships and donations, the drawing up of compliance statements can be quite resource intensive. Thus, our team has set up an automated “compliance statement generator” based on targeted questions with answers linked to respective “text blocks”, which automatizes the process of drawing up compliance statements. This allows the Compliance Officers to check and adjust the prepared template, instead of drawing up a new statement in each individual case.

What is a cause, business or otherwise, that you are passionate about? Why is this?

I am very passionate about our whistleblowing policy and investigation of whistleblowing reports. The Heraeus case in Germany again shows, how important it is to have a functioning system of investigating information provided by employees and how ignoring them – or even half-heartedly investigating them – can be damaging and expensive. To foster the confidence of employees that they come forward and speak-up, ensure that they have a feeling of trust that whistleblowing reports are properly dealt with, is an important part of the job of a Compliance Officer. This requires that compliance departments often deal with HR reports, evaluating business cases, or with product safety reports outside of the core compliance topics, which can pose lots of challenges, as well as opportunities.