Business Compliance

FAIR COMPETITION



We see the avoidance of corruption and anticompetitive behaviour as an essential management task. The potential damage that a company may incur as a result of corrupt or anti-competitive behaviour on the part of individual employees can be significant.

Even if STRABAG generates much of its revenue in countries with a low risk of corruption, the international nature of its business means that some activities are also performed in countries with a higher corruption risk, as measured, for example, by the Corruption Perceptions Index. Transparent procedures to minimise risk are required in all regions, especially during contract award or in negotiations with partner companies and subcontractors.

STRABAG acted by implementing an ethics business compliance system in 2008 to avoid violations of the law and any resulting material and immaterial damage and to maintain the company’s good reputation as a business partner, contractor and employer. The company has been continuously developing the system ever since. With extensive measures for employees and leadership, STRABAG is working to promote compliant and ethical behaviour and to create a strong corporate culture based on partnership and trust.

Projects and initiatives

Experience has shown that a functioning BCMS not only has a positive impact internally, but also yields great advantages externally. This is one of the reasons why STRABAG pursues a corporatewide certification process. Fair competition is one important component in this process. STRABAG wants to raise awareness of the issue not only among top management, but also among decisionmakers at other levels. The past has shown that group managers in particular have comparatively broad decision-making authority but receive less training on this topic than the management level. For this reason, a separate group manager training course will be rolled out in an online format in 2023.

The sanctions list review also proved to be of great importance in 2022, not only for ourselves but also for our external stakeholders. We sharpened our criteria for the stakeholder review (see item “Internal Memorandum”), which we believe sends a positive message to these stakeholders. We also conducted a stakeholder analysis during the reporting period in order to identify and better understand the needs and expectations of a variety of different parties. The stakeholder analysis is based on the criteria set out in ISO 37301.

Following STRABAG AG Austria’s successful certification by Austrian Standards to ISO 37001 and ISO 37301 for the prevention of cartel and competition violations and for combating corruption, and confirmation of the effectiveness of the compliance management system in the monitoring audits, the first-ever monitoring audit for corporate-wide certification was carried out in July 2022. The certification is divided into the three country clusters of Austria, Germany and the remaining Group countries. The monitoring audit for Austria was completed in summer 2022.

Certification was awarded to STRABAG SE and all Austrian companies. The scope of the certification in accordance with ISO 37001 and ISO 37301 again includes the issues of anti-corruption and cartel law. STRABAG SE was able to demonstrate the effectiveness of the Business Compliance Management System (BCMS) in all Austrian companies in order to obtain the certification.

In a second step, all of STRABAG SE’s German companies were audited and certified during the fourth quarter of 2022. In the first half of 2023, all other companies of STRABAG SE will be reviewed for the effectiveness of the BCMS, so that corporate-wide certification of STRABAG SE can be expected in the middle of 2023.

Objectives and indicators

The overriding objective of the STRABAG Compliance Management System is the complete avoidance of non-compliant behaviour.

As a result of the Management Business Compliance Reporting, which became mandatory for all divisions, central divisions and central staff divisions for the first time in 2021 and must subsequently be carried out annually, the assessment of corruption risks is to be updated annually and continuously improved. The risks identified in the course of the investigation were taken into account accordingly in the design of the new STRABAG BCMS.

Communication and training about anti-corruption policies and procedures

STRABAG implemented a comprehensive training concept to communicate to employees the guidelines and procedures for combating corruption and anti-competitive behaviour.

Training rate has been slightly increased in 2022 :

• Training course “Anti-Corruption and BCMS”: 86%
• Training course “Cartel Law”: 89%
• Refresher course “Business Compliance”: 64%
  

• Total number and nature of confirmed incidents of corruption: In the 2022 reporting year, there was no confirmed incident of corruption.
• Total number of confirmed incidents in which employees were dismissed or disciplined for corruption:There were no confirmed incidents in which employees were dismissed or disciplined for corruption.