Controversial arms exports, climate protection and dividends despite short-time working: Our questions to Rheinmetall

Questions on dividend and appropriation of net income:

  • Last year you made use of short-time working, but now you want to distribute a dividend of 2.00 euros per share and thus 86 million euros in total. In your dividend policy, have you taken into account the current situation with regard to short-time working allowance, that this is currently de facto tax-financed and therefore more of a state aid in the Corona crisis than an insurance benefit?
  • In your annual report, you state that you have saved personnel costs of 33 million euros through short-time working. According to trade union information, unlike the majority of other companies in the sector, you have not topped up your employees’ short-time allowances. Is this true? If so, why do you consider the distribution of dividends to be more important than top-up payments for your employees?
  • To what extent have you received reimbursement of employer social security contributions in connection with short-time work?

Questions on climate protection and climate targets:

  • Rheinmetall is committed to taking ESG targets into account. Management bonus payments are also partly dependent on the achievement of certain ESG targets. What are the specific targets?
  • Arms production and the use of weapons (systems) generate enormous amounts of greenhouse gas emissions. To what extent can climate protection be reconciled with the goal of achieving consistently high growth rates?
  • Why have you not yet collected any data for greenhouse gas emissions in Scope 3?
  • In the current annual report, you only write that the “expansion of reporting on scope 1 and scope 3 emissions will be prepared in several phases in the coming years”. Given that other companies have been doing this for years: By what date exactly do they plan to fully publish your GHG emissions in Scope 1, 2 and 3?
  • Can you at least roughly estimate the emissions in scope 3 in relation to scope 1 and 2 as a percentage? If so, what is the ratio?
  • You want to be climate neutral by 2035. Does this also apply to the emissions of your value chains (Scope 3)?
  • Do you have climate targets in relation to Scope 3? If yes, what are these? If not, do you plan to set corresponding climate targets for this purpose?
  • What is Rheinmetall’s absolute CO2 reduction target across the Group by 2025 and by 2030?

Questions on the Annual Report:

  • What is the current status of the negotiations with the German government on compensation for damages due to the revoked license to export military trucks to Saudi Arabia? What is the amount of compensation or has another buyer already been found (name new buyer if necessary)?
  • What is the current status of the investigation by the South African Department of Labor into the cause of the 2018 explosion at the Rheinmetall Denel plant in South Africa, which killed eight workers? To what extent do you expect new findings here in contrast to the Rheinmetall internal investigation of 2019, which assumed that the incident was accidental? Could the outcome of the investigation possibly have an impact on compensation payments that may then still have to be made?
  • In the last conference call with analysts, you said, Mr. Papperger, that exports from South Africa to Saudi Arabia had restarted, but that the “situation is not yet fully clarified.” Can you please discuss what that means exactly?
  • In the same conference call, Mr. Papperger, you emphasized that Rheinmetall’s export risk is currently weakening as its involvement in sensitive markets is decreasing. To what extent are you prepared to continue serving sensitive markets in the future?
  • Last week, Rheinmetall joined the UN Global Compact and announced its intention to “commit to human rights within the scope of its own influence”. What does this mean in concrete terms? To what extent does this include the willingness to check whether Rheinmetall weapons have also been used in actions contrary to international law in which civilians have been harmed? If so, to what extent are you prepared to compensate the families of victims?
  • In October of last year, the investor Janus Hendersen sold a large portion of his shares in Rheinmetall, which resulted in a short-term drop in the Rheinmetall share price. What were the specific reasons for this and what do you intend to do to prevent such divestments in the future?
  • You state that you have many financial partners in order to avoid cluster risks. With which or how many financial institutions do you cooperate in Germany, in Europe and worldwide? What are their principal banks?

Questions about RWM Italia:

  • Orders to what extent are affected by the revocation of export licenses from Italy to Saudi Arabia and the UAE? What consequences does this decision have for the business of its Italian subsidiary?
  • To what extent is RWM Italia sticking to its plans to expand defense production in Italy? To what extent is Rheinmetall (or RWM Italia) considering a conversion of the plant?
  • Currently, RWM Italia’s new plant cannot go into operation due to pending legal proceedings. At the same time, RWM has invested tens of millions in the expansion of the Domusnovas plant. What is the estimated amount of losses in terms of lost revenue as a result of the suspension of production and the ongoing administrative proceedings?
  • To what extent does Rheinmetall still believe that it was a sensible investment to invest a double-digit million amount in the expansion of the plant?
  • In view of the fact that the complaints filed with the Italian administrative courts indicate violations of EU directives, there is a possibility that the company may be held accountable by the European Commission. How high does Rheinmetall assess this risk and what are you trying to do about it?
  • As mentioned above, on April 27, 2021, the Administrative Court in Rome dismissed RWM Italia SpA’s appeals against the government’s decision to halt exports to Saudi Arabia and the UAE. In the decision, the court stated that the human rights of civilians in Yemen must take precedence over the economic interests of RWM Italia SpA. Will you appeal the decision of the Italian Administrative Court?
  • On February 26, 2021, the Investigating Judge in Rome ruled that the Prosecutor’s Office will continue the criminal investigation against managers of RWM Italia SpA. The prosecutor confirmed that the remains of RWM Italia found at the site of the attack may have been exported in November 2015. What is your opinion of this court ruling?
  • Has Rheinmetall AG taken any measures to prevent such deadly incidents from happening again in the future? If so, which ones?
  • Recently, there has been an increase in information about possible cooperation or joint ventures between Rheinmetall and the Italian defence companies Fincantieri and Leonardo. To what extent and in what form are increased cooperations planned here?
  • Would it be possible to provide a detailed account (by type and quantity) of trade between the Group’s subsidiaries, which are represented in particular in Italy, Spain and Switzerland, with regard to the production and maintenance of guns and artillery?
  • Via the Italian subsidiary RWM Italia, an order in the triple-digit millions has been placed with Qatar in recent years. Why was an almost equal partnership or joint venture established with Qatar for this business? To what extent is there a transfer of technology or know-how from other Rheinmetall locations for this order? What kind of products are involved? Why was it necessary to submit a “foreign-to-foreign” license application to the Italian authorities for the sale?

Questions on donations:

  • Were there any donations made by Rheinmetall AG or one of its subsidiaries to political parties in the years between 2018 and 2020? If yes, please break down the answers by amount, receiving party incl. association and date of donation.
  • Did Rheinmetall engage in so-called party sponsorship during the aforementioned period? If yes, please break down the answers by amount, receiving party incl. association, date and type of sponsorship.
  • In which German metal associations or corresponding associations is Rheinmetall AG or one of its subsidiaries a member?
  • How much did Rheinmetall sponsor the German Council on Foreign Relations (DGAP) last year? (DGAP) financially, including any membership fee?
  • In the past year, how much financial support did Rheinmetall provide to the Fördererkreis der Deutschen Gesellschaft für Auswärtige Politik e.V., including any membership fees?
  • What payments or non-cash benefits did Rheinmetall make to party-affiliated foundations last year? Please break down the answer by amount and recipient.
  • What payments or membership contributions to other German think tanks, lobby or interest groups, and organizations such as the Förderkreis Deutsches Heer did Rheinmetall make in 2018-2020? Please break down the answer by amount, recipient and year.
  • What payments or membership fees to foreign think tanks, lobby or interest groups as well as comparable organizations did Rheinmetall make in the period 2018-2020? Please break down the answer by amount, recipient and year.

Questions regarding the ammunition business:

  • From which countries does Rheinmetall have a license in connection with the export of MK series bombs?
  • From which countries does Rheinmetall have a license in connection with the export of artillery and tank ammunition in calibers 105mm to 155mm?
  • From which countries does Rheinmetall have a license in connection with the export of mortar shells in calibers 60mm to 120mm?
  • From which countries does Rheinmetall have a license in connection with the export of fuzes?
  • Does Rheinmetall have a Swiss export license (one-time or continued) for the export of ammunition or the associated technology transfer? If so, which ammunition types and which recipient states are covered by this? Are these individual or collective export licenses?
  • Were fuzes exported by RWM Schweiz AG between 2015 and 2020 or were exports in connection with this authorized? If so, which ammunition calibers and which recipient countries were involved?
  • Did the decision of the US administration under President Biden in February 2021 to stop supplying Saudi Arabia and the UAE with ammunition, at least for the time being, have any influence on Rheinmetall AG’s business? If so, in what form?
  • What types of ammunition are currently planned to be manufactured in Australia at some point in the future?
  • What is the total number of ammunition factory projects completed by Rheinmetall to date, including those currently in progress?
  • In which year was the respective contract concluded for the ammunition factories?
  • Does Rheinmetall Lingsdail Pty. manufacture fuzes for the following ammunition types: a) 155mm b) 120mm c) MK bombs d) mortar shells? To which countries have Rheinmetall Lingsdail fuzes been exported to date?
  • With which countries does Rheinmetall have business relations in Africa?
  • Has Rheinmetall exported ammunition to Zimbabwe since 2015?
  • What knowledge does Rheinmetall have about where the armaments it sells, and especially the ammunition, are actually used? What measures does Rheinmetall AG take to monitor this?
  • At which production sites in the USA is Rheinmetall ammunition manufactured – by Rheinmetall itself or under license by other companies? 

Questions about RMMV trucks in war zones:

  • What does Rheinmetall know today about the use of Pantsir missile systems on trucks from MAN or Rheinmetall MAN Military Vehicles in Libya, mentioned by a UN expert report as early as December 2019?
  • In what form did Rheinmetall make inquiries in this regard in the United Arab Emirates, which had purchased these trucks and then, according to the UN, transported the Pantsir to the civil war country of Libya, in violation of the UN arms embargo?
  • In what way did Rheinmetall support the German government’s reconnaissance efforts in the case of the Pantsir systems on MAN or Rheinmetall trucks identified in Libya?
  • According to a recent UN expert report from March 2021, Turkey also deployed Koral jamming systems in Libya. According to brochures from the manufacturer Aselsan, these roll on vehicle systems from MAN and Rheinmetall respectively. To what extent does Rheinmetall support efforts to clarify how German technology was used to break the UN embargo?
  • According to a recent UN expert report from March 2021, Turkey also used T-122 rocket launchers in Libya. According to brochures from the manufacturer Roketsan, these roll on vehicle systems from MAN and Rheinmetall respectively. To what extent is Rheinmetall supporting efforts to clarify how German technology was used to break the UN embargo?


  • Has Rheinmetall cooperated with universities in the development of new products since 2019? If yes, please break down the answer by university, research project and time period
  • In which projects at EU level, especially within the so-called “Permanent Structured Cooperation” (PESCO), is Rheinmetall involved? In what form?
  • Does the planned change in the object of the company (agenda item 12) also involve a strategic realignment of Rheinmetall AG in the field of information technology or does this alignment merely reflect current business activities?
  • What products does Rheinmetall currently offer for sale in the field of information technology? How is the product range offered to change in the coming years?
  • Is there a binding commitment by Rheinmetall AG not to participate in the development of autonomous weapons systems (AWS) that take away human control over the use of weapons? If no, please give reasons.
  • What products does Rheinmetall AG offer in the Defence sector that have autonomous operational functions? Is Rheinmetall AG involved in the development of products or research projects in the Defence sector that have autonomous operating functions?
  • Is Rheinmetall AG involved in the development of products in the Defence sector that are to have artificial intelligence (AI), e.g. machine learning?
  • Is Rheinmetall AG involved in research projects in the field of artificial intelligence (AI)?

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