Integrity@RUAG International

Compliance & Governance is responsible for ensuring a properly functioning compliance program at RUAG International.  Some areas the Compliance & Governance organization is responsible for are: defining and managing group directives, training, managing the whistleblower system, and organizing trade- and commercial compliance.

Compliance & Governance reports directly to the Audit Committee and the Board of Directors bi-annually.

Integrity@RUAG International relies on the continuous assessment of the organization’s risk exposure.  Necessary compliance initiatives and measures are defined, and resources are allocated to effectively mitigate compliance-related risks.

Compliance documents (codes, directives, regulations, supporting documents, and procedures & processes) are continuously revised to address relevant changes in the regulatory environment.

RUAG International applies a zero-tolerance policy to any form of bribery and corruption.

At RUAG International, our employees, management, and Board of Directors commit themselves to prevent corruption or bribery of any kind. 

Our remuneration arrangements are designed to ensure that they do not undermine our commitment against bribery and corruption.

RUAG International does not make donations to political parties.

To prevent the impression of bribery or corruption, RUAG International’s rules and regulations must always be followed when giving or receiving gifts or benefits. The following conditions must be met before such gifts can be provided or accepted:

• Fulfill the “good faith” principle;
• Should be appropriate in nature;
• Must be of reasonable value (follow RUAG International’s value thresholds);
• Should not be intended to serve as an influence or to affect decision-makers;
• Should not be used to facilitate or expedite public or governmental actions;
• May not be used for prohibited or dubious purposes;
• Exceptions may apply in case of danger to personal health and safety.

Any gifts given to a third-party must be recorded accurately in RUAG International’s financial books and records.

Our business partners are expected to provide the same commitment to prevent bribery and corruption and are therefore reviewed on their conduct on an individual basis.  We are committed to terminating transactions with third-parties if there are grounds for suspicion of wrong doing.

RUAG International takes great care to ensure that everyone working for the company is familiar with and follows its Code of Conduct and company directives. Group directives have been drafted in understandable language accompanied by in-person or e-learning training modules.

Modules of training are tailored to specific topics and made available to both current and new employees.  Every three years, employees must undergo refresher training and e-learning on the compliance program.

As a company owned by the Swiss Confederacy, RUAG International must be aware of its responsibilities as a provider of military applications for aerospace and defense. All exports of military & defense applications and dual-use products must comply with international law, Swiss international obligations, and Swiss foreign policy principles.

Military & defense applications include exporting defense products and defense-related services to foreign customers (i.e., outside Switzerland). RUAG International is subject to and adheres the local laws of the countries it operates in as well as Swiss export control laws, in particular the Federal Act on War Material (KMG), the Federal Act on the Control of Dual-Use Goods, and of Specific Military Goods (GKG), the Federal Act on the Implementation of International Sanctions, Embargo Act (EmbG) and the Federal Act on Private Security Services Provided Abroad (PSSA).

RUAG International delivers military applications exclusively to unambiguously identifiable, reputable business partners, thereby contributing to security, independence, and stability.

Conflicts of interest pose a threat to RUAG International as an organization as well as a significant corruption hazard. As a result, RUAG International has issued a Regulation that sets the basic rules to handle any actual, potential, or perceived conflicts of interest to avoid any negative consequences for all its employees and RUAG International as a company.

To prevent possible conflicts of interest on a leadership level, the Swiss Confederation, as the sole shareholder of RUAG International, controls all decisions at the General Meeting, including the election and remuneration of Board Members and dividend resolutions. RUAG International is also required to disclose annually the details of the nomination process, appointments, composition, and remuneration of its Board of Directors.

RUAG International also expects proper conduct from all of its business partners, including its customers, suppliers, service providers, and their supply chains. These standards are established and communicated to all third-parties.

RUAG employs a standardized contracting process for third-party engagements. In principle, contracts with third-parties that support sales activities always require compliance approval.  Also, detailed, and comprehensible anti-bribery and corruption clauses are included in contracts.

RUAG International also requires the use of template contracts that include the following provisions:

• RUAG International’s right to immediately terminate the contract and claim compensation if the third-party violates the ban on corruption.
• RUAG International’s right to regular reporting from the third-party (particularly from agents) on past and upcoming activities. If the third-party does not fulfill this obligation, a penalty will be imposed, and/or the contract may be terminated.
• Depending on the specific risk exposure, RUAG International may ask for a statement from an independent, local legal expert confirming that the third-party is a corporation duly organized under applicable laws and that the contractually agreed activity and the compensation to be provided is admissible.
• RUAG International has set upper limits for agents’ commissions, usually determined by a percentage of the contractual volume brokered. In addition, RUAG International specifies a declining commission scale for high-volume customer contracts and always requires a cap on the agent’s commission in absolute numbers.
• RUAG International may request external service providers to conduct background checks on the third-party, its shareholders, and any other affiliated legal entities or natural persons.  The request will depend on the specific risk exposure.

It is encouraged to immediately report irregularities or violations of the Code of Conduct or any company directives immediately. Violations of any kind are not acceptable and will be appropriately sanctioned.

Employees and third-parties worldwide can utilize RUAG International’s whistleblowing system either online (https://beyondgravity.speakup.report/beyondgravity) or by phone (see here for local phone numbers) if they suspect or observe irregularities or violations. The system allows anonymous incident reporting and confidentiality within RUAG International’s Compliance & Governance department. Incidents of known or suspected violations reported in good faith are protected against retaliation.

Any retaliation against employees who have reported violations in good faith or false allegations against colleagues or managers are subject to disciplinary measures and sanctions. 

Disciplinary measures or sanctions can range from reprimands and warnings to dismissal and civil claims for compensatory damages and criminal prosecution, depending on the severity of the violation.