14. Employment Rights

The company reports on how it complies with nationally and internationally recognised standards relating to employee rights as well as on how it fosters staff involvement in the company and in sustainability management, what goals it has set itself in this regard, what results it has achieved thus far and where it sees risks.

Our business activities are based on a common corporate culture with shared values. The Group's set of values embraces five principles that apply to all employees: integrity, reliability, innovation, results orientation and sustainability. They are all underpinned by the principle of safety - this applies to all HOCHTIEF's work - both operationally and strategically.

HOCHTIEF cherishes a transparent management well advanced over the legal requirements. We align activities with the recommendations of the Government Commission on the German Corporate Governance Code. HOCHTIEF is an active participant ("signatory") of UN Global Compact and follows the "Code of Responsible Conduct for Business".

Every employee is important to us, so we take the legal requirements regarding employee rights very seriously. Respect and fairness characterize the trustful cooperation with us - we expect the same from our business partners and customers. These rules are laid down in our Code of Conduct and directives. Our Code of Conduct complies with both the ILO core labour standards and the German Corporate Governance Code (DCGK). It is binding for HOCHTIEF Aktiengesellschaft and the Europe division.

Our HOCHTIEF Americas and HOCHTIEF Asia Pacific divisions have incorporated the requirements into their codes of conduct, which means that German standards are also established in our international companies.

The exchange with our employees and their opportunities for co-determination are important to us. This is done either directly through open and constructive dialogue between employees and superiors or through elected stakeholders. Many employees continue to receive support from trade unions, some of which they are members of. In Germany, 97.1 percent of employees are represented by works councils; a European works council is responsible for the European units. Employees in the other subsidiaries are also represented by trade unions: 23.0 percent in the HOCHTIEF Americas division and 65.4 percent in the HOCHTIEF Asia Pacific division.

A critical requirement for all project teams is to be well informed and trained on occupational safety, health, and environmental protection. We involve and sensitize the workforce to ensure everyone understands environmental issues, for example by peronsal training, on-site instruction, and training presentations.

Staff at the OSHEP Center coordinate occupational safety matters at Group level and report directly to the
Executive Board. They remain in regular contact with the divisions’ central liaisons. Other responsible officers in the operating companies are charged with implementing occupational safety guidelines, laws, and standards.



Opportunity and risk situation in the HOCHTIEF Group: Employees

We attach top priority to occupational safety and health protection for our employees. Effective occupational safety guards against project risks, since accidents at work also have a negative impact on profitable project execution. Deficiencies in the area of occupational safety can also harm the company’s reputation. Safety is the foundation underpinning all of our Group’s guiding principles. Project hazard assessments serve to identify safety risks on project sites and in our offices as well as to counter those risks either preventively or with targeted action. The lost time injury frequency rate (LTIFR) is a non-financial key performance indicator. By 2030, we aim to reduce this figure to 0.9 at Group level. This underscores the importance of safety for HOCHTIEF.

Our focus is on proactively avoiding work accidents and workplace-related illness. Regular action days, intranet and poster campaigns as well as training raise employee awareness of issues surrounding occupational safety, health, and environmental protection.


CR organization

The principle of sustainability is coordinated by the specialist division Corporate Responsibility. This is laid down in our CR directive, wich defines Group-wide standards. The work of both the CR function and the CR bodies (CR Committee, Sustainability Competence Team) is geared toward the ongoing strategic and operational fine-tuning of sustainability at HOCHTIEF. The executive board is regularly integrated in these works and processes. The importance of sustainability, especially through holistic project management and support of the UN Sustainable Development Goals, is communicated to investors and other interest groups by the executive board (see Letter from the CEO Marcelino Fernández Verdes).

Further information on CR organization at HOCHTIEF can be found under criterion 5 "Responsibility".


Research and development at HOCHTIEF

Our research and development work makes a significant contribution to HOCHTIEF's sustainable activities. Our employees develop future-oriented ideas for sustainable solutions centrally, but also at divisional and project level. In addition to the economic benefits, these make a significant contribution to achieving our ecological and social goals.


International activity

Compliance - the binding observance of all internal and external rules - plays an important role at HOCHTIEF. As an international construction services provider, HOCHTIEF is active in countries with very different values, political systems and legal systems - and is committed to them.

Binding principles of conduct also apply throughout the Group: All employees of our Group companies are required to act in accordance with the rules laid down in the HOCHTIEF Code of Conduct and to adhere to internal guidelines on compliance-relevant issues. We demand the same from our contractual partners and subcontractors.

15. Equal Opportunities

The company discloses in what way it has implemented national and international processes and what goals it has for the promotion of equal opportunities and diversity, occupational health and safety, participation rights, the integration of migrants and people with disabilities, fair pay as well as a work-life balance and how it will achieve these.

Diversity

HOCHTIEF has signed the Diversity Charter, clearly stating its position on diversity, tolerance, mutual regard and fairness. We work together with people who differ in many ways, including age, gender, nationality, religion and social background.

Our goal is to promote diversity and the awareness of its importance, as shown by many initiatives pursued in 2018: Girls' Day events, programs focusing on the inclusion of socially disadvantaged groups, as well as awards from outside organizations for equal-opportunity efforts within the Group. CIMIC and Turner held training sessions in dealing with unconscious bias again in the reporting year. Flatiron launched the Talent Growth Initiative in 2018 to support underrepresented groups.

We are responding to demographic change and its diverse influences with a broad-based age structure. A good distribution of expertise and experience along with long-term transfer of specialized knowledge contributes to the successful implementation of our projects.

In the construction industry, people with disabilities can generally only be employed in administrative positions. At job interviews with people with severe diabilities, a disability officer is always present to ensure all options are fully explored. The proportion of severely disabled employees at HOCHTIEF in Germany was 3.8 percent as of December 31, 2018. Since we fall below the legally prescribed five percent, we pay corresponding compensation payments.

Occupational safety and health

Since our core business is construction, safety is a top priority in our day-to-day work and accident-free projects are our primary goal. For this reason, safety is anchored in the Code of Conduct, and the accident frequency lost-time injury frequency rate (LTIFR) plays a key role in our company as a non-financial performance indicator.

In 2018, our activities focused above all on near misses and unsafe situations, also discussed at the annual Occupational Safety Day held on project sites and in offices. To further raise awareness and provide notably industrial employees with a suitable feedback tool, we started setting up information boards at selected construction sites in Germany. Those involved can report hazardous conditions, near misses and also offer suggestions for improvements. This approach has proven to be successfully on projects in the United Kingdom.

Organization

At HOCHTIEF, the organization of occupational safety, health and environmental protection (OSHEP) is based on a guideline that defines Group-wide standards in this area. The OSHEP Center, our internal competence center for occupational safety, is responsible for organizing and fine-tuning measures in these areas. Employees at the OSHEP Center coordinate occupational safety matters at Group level and report directly to the Executive Board and remain in regular contact with the cetral liaisons of the division.

In addition to our prescribed standards, our companies develop their own supplementary processes and structures to integrate occupational safety and health protection in all project phases. These processes and structures are based on international standards such as BS OHSAS 18001. In 2018, 85.1 percent (2017: 87.1 percent) of HOCHTIEF's active employees worked in certified areas.

Early hazard indentification

HOCHTIEF places high demand on the performance and understanding of their subcontractors and suppliers in the fields of occupational safety, health, and environmental protection. To ensure this, all parties involved are required to sign HOCHTIEF's Code of Conduct for Business Partners before construction begins. The selection of our subcontractors is also subject to high demands on their performance in terms of occupational safety, health and environmental protection.

In project activities, the efficiency control of occupational safety and environmental protection measures is carried out by the respective safety experts of the units. The OSHEP Center is supported by HOCHTIEF's internal audit department that regularly checks up on the structures and measures implemented at construction sites.

Work-related accidents and illnesses

Since safety is a central principle of our corporate principles and has overall relevance for the entire Group, the lost-time injury frequency rate (LTIFR) is a non-financial performance indicator at HOCHTIEF. The figure records accidents per million hours worked and takes into account accidents with at least one day of absence in accordance with the standards of the International Labour Organisation ILO. In 2018, the LTIFR was 1.37 (previous year: 1.23) due to an increase of the number of accidents in the HOCHTIEF Europe division. Our goal is to reduce the frequency of accidents in the Group to 0.9 by 2030.

Accidents and incidents, including near misses, are recorded using a structured reporting system. All companies define accidents at work on the basis of the guidelines of the Recording and Notification of Occupational Accidents and Diseases of the International Labour Organization (ILO). We use the findings to develop concrete counter- and preventative measures. During feedback interviews, managerial staff help employees to process situations that gave rise to accidents. More and more frequently, we are currently pursuing behavioural-based prevention approaches in order to sustainably avoid dangerous situations.

In addition, we offer employees the "Fit for Work - Fit for Life" health programme, which focuses in particular on the well-being of our employees: the focus in 2018 was on drug abuse and addiction. 

Work-life balance

We support the individual life plans of all employees through our working conditions. We offer various measures and programs designed to give them personal space to plan their lives, including part-time models, the possibility of home office, flexible working hours, and telecommuting. These options allow employees to better reconcile professional interests with private or family concerns.

Employees can check, improve or protect their health through targeted preventive measures. Check-up examinations, health screenings and vaccinations are offered at several locations. In addition, we offer further occupational safety and health seminars within our qualification programme.

Competitive salaries

Regular reviews of our principles for fixed and variable remuneration components enable us to pay in line with market conditions and performance. The objective classification of remuneration is supported by internal analyses and external benchmarks, which also enables us to meet the requirements of the German Corporate Governance Code. Regardless of gender, the remuneration of each individual employee is largely determined by his or her job, qualifications, responsibilities and experience.

Pensions

In order to make a contribution to pension provision beyond the statutory pension systems, we offer our employees at many locations various pension provision models - for example insurance offers or the possibility of deferred compensation. The models offered depend on the framework conditions and pension systems in the local countries.

Further information can be found in the 2018 Group Report starting on page 97.

16. Qualifications

The company discloses what goals it has set and what measures it has taken to promote the employability of all employees, i.e. the ability of all employees to participate in the working and professional world, and in view of adapting to demographic change, and where risks are seen.

Continuous feedback is important for the personal development of our employees. In addition to the daily feedback on performance, we rely on the Group-wide structured appraisal interview, which takes place once a year with each employee. The interview is a constructive dialogue based on partnership between the employee and his or her superior. The mutual feedback gives both parties a deeper insight into each other's work and professional ideas. At the same time, the interview shows the employee his strengths and areas of development. We want to promote and understand lifelong learning as an important element of our employee development and as a central element in the implementation of our personnel strategy.

HOCHTIEF focuses on further training to qualify employees for current and future tasks. With institutions such as the HOCHTIEF Academy and Turner University, we offer a wide range of development opportunities in this area - for our young colleagues as well as for employees with many years of professional experience. The offer is possible both directly at the workplace and through an extensive, demand-oriented further training programme. Among other things, they impart know-how in various specialist areas, on occupational safety topics or offer opportunities for personal development. This enables our employees to receive comprehensive further training in all areas.

Our goal is to identify and promote our talents through our offerings, for both expert and management careers. Through our training facilities, we ensure that all employees - from trainees and experts to managers - can further develop their professional, methodological and personal skills. Overall, our employees continued their training for an average of 20.5 hours in 2018 (2017: average of 24 hours). We have thus clearly exceeded our target of at least 13 hours. In the coming years, we want to keep the average number of training hours per employee per year at a high level.

This year we offered new event series, such as a training series for site managers, which complements the existing project manager training. In addition, HOCHTIEF Engineering and HOCHTIEF Infrastructure launched a joint initiative for design managers and project managers at the beginning of 2017. In this qualification measure, participants are taught new knowledge about planning, coordination and control processes. Our subsidiary Flatiron also launched a project series for project management executives in the year under review. CIMIC also launched a revised leadership program involving executives from Australia and Hong Kong.

In the year under review, 34 young people in Germany began training with us. The proportion of trainees is 2.7 percent as of December 31, 2018, with a total of 94 trainees (2017: 94).


Opportunity and risk situation in the HOCHTIEF Group: Employees


All employees contribute decisively to HOCHTIEF’s business success. In this connection, our human resources strategy delivers a valuable contribution to the HOCHTIEF corporate strategy. While competition for good employees has become significantly fiercer, HOCHTIEF is successful in meeting its demand for qualified staff. It nonetheless remains our goal to continue enhancing our positive image and attractiveness as an employer for different target groups and skill profiles. Furthermore, we want to develop and make optimum use of our workforce potential. If we are able to exceed our expectations in this regard with a significant and lasting increase in workforce qualification levels, this will have a positive impact on our business performance.

For early detection of potential personnel risks, we
have established risk management in the human resources function based on our risk guide. Since January 2014, a systematic survey has captured major risk categories such as skill, motivation, staff turnover, and succession risk together with the potential impacts on HOCHTIEF. The risk management classification scheme in human resources is regularly reviewed for new risks and adapted as necessary.

Based on the most recent surveys, we classify personnel risk as low.

Key Performance Indicators to criteria 14 to 16

Key Performance Indicator GRI SRS-403-9: Work-related injuries
The reporting organization shall report the following information:

a. For all employees:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number and rate of fatalities as a result of work-related injury;
ii. The number and rate of high-consequence work-related injuries (excluding fatalities);
iii. The number and rate of recordable work-related injuries;
iv. The main types of work-related injury;
v. The number of hours worked.

You will find the remaining numbers c-g of the indicator SRS 403-9 in the GRI standard and may additionally report them here.


Key Performance Indicator GRI SRS-403-10: Work-related ill health
The reporting organization shall report the following information:

a. For all employees:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.
b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:
i. The number of fatalities as a result of work-related ill health;
ii. The number of cases of recordable work-related ill health;
iii. The main types of work-related ill health.

You will find the remaining numbers c-e of the indicator SRS 403-10 in the GRI standard and may additionally report them here.

a.
i. 0
ii. 2018 Severity Rate for all employees of the HOCHTIEF Group: 40,6
iii. Significant types of injury in the HOCHTIEF Group (all employees): lacerations, wounds, fractures, contusions, sprains, cuts/stab wounds, internal injuries (see Group Report, p. 105, table 6) 
  (view graph 6 on page 105 in the HOCHTIEF Group Report).
v. Total number of hours workd (all employees): 157.902.032 

b. 
i. 3
ii. 2018 Severity Rate for all employees of the HOCHTIEF Group: 40,6
iii. Significant types of injury in the HOCHTIEF Group (all employees): lacerations, wounds, fractures, contusions, sprains, cuts/stab wounds, internal injuries (see Group Report, p. 105, table 6) 
v. Total number of hours workd (all employees): 157.902.032

GRI SRS-403-10: not applicable.

Key Performance Indicator GRI SRS-403-4: Worker participation on occupational health and safety
The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization:

a. A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers.

b. Where formal joint management–worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees.

At HOCHTIEF in Germany, the Occupational Health and Safety Committee (Arbeitssicherheitsauschschuss, ASA) meets four times a year as required by law. In addition to those responsible for occupational health and safety, participants include management and representatives of the works council. There are also regular occupational health and safety meetings organized by the AGUS Center, the internal competence center for occupational safety, health and environmental protection (AGUS) as well as inspections and activities onsite. There are similar committees in the individual Group companies. 

Findings from the evaluation of incidents near-miss are integrated in the work of  AGUS Center. 

The management system is certified accoring to OHSAS 18001, the Group coverage stands at 85.1% (in relation to the number of employees).

Key Performance Indicator GRI SRS-404-1: Average hours of training
The reporting organization shall report the following information:

a. Average hours of training that the organization’s employees have undertaken during the reporting period, by:
i. gender;
ii. employee category.

Average hours of training in 2018 (all employees): 20,5

Key Performance Indicator GRI SRS-405-1: Diversity
The reporting organization shall report the following information:

a. Percentage of individuals within the organization’s governance bodies in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

b. Percentage of employees per employee category in each of the following diversity categories:
i. Gender;
ii. Age group: under 30 years old, 30-50 years old, over 50 years old;
iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

a.
Supervisory Board: 
Since the Supervisory Board elections in spring 2016, the Supervisory Board has comprised five women (31,25%) and eleven men.
ii. under 30: 0; 30-50: 18,75% (3); over 50: 81,25% (13)

Executive Board:
0% female, 100% male
ii. under 30: 0; 30-50: 0%; over 50: 100%

b. 
i. 
Employees (total workforce): 55 777 
– of which men: 87,273% (47 838) 
– of which women: 12,727% (7 939)

White-collar workers (incl. apprentices): 26 255
– of which men: 73,077% (19 545) 
– of which women; 26,923% (6 710) 

Blue-collar workers (incl. apprentices): 29 522 
– of which men: 96,552% (28 293) 
– of which women: 3,448% (1 229)

ii. 
– under 30: 23,5%
– 30–50: 57,7%
– over 50: 22,9%

Key Performance Indicator GRI SRS-406-1: Incidents of discrimination
The reporting organization shall report the following information:

a. Total number of incidents of discrimination during the reporting period.

b. Status of the incidents and actions taken with reference to the following:
i. Incident reviewed by the organization;
ii. Remediation plans being implemented;
iii. Remediation plans that have been implemented, with results reviewed through routine internal management review processes;
iv. Incident no longer subject to action.

a. Compliance with human rights and the active prevention from human rights violations are part of HOCHTIEF's self-conception. Early-on, HOCHTIEF has shown this by commitments, e.g. ILO and UN Global Compact. For us, Human Rights and employee rights are essential issues. Our corporate culture is based in a common understanding of resepct and fairness. The HOCHTIEF Code of Conduct bindingly outlines all guidelines for our employees. 

In case of a suspicion on compliance breaches - part of which are discimination issues - Corporate Cojmpliance or Corporate Audit conduct compliance audits. The audit function also checks whether compliance processes and the respective directives are adhered to. In 2018, 64 audits on compliance issues were carried out.

17. Human Rights

The company discloses what measures it takes, strategies it pursues and targets it sets for itself and for the supply chain for ensuring that human rights are respected globally and that forced and child labour as well as all forms of exploitation are prevented. Information should also be provided on the results of the measures and on any relevant risks.

HOCHTIEF committed itself to the standards of the International Labor Organization (ILO) in 2000 and as a signatory to the UN Global Compact in 2008 to support and respect international human rights.

The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.

HOCHTIEF sees key areas of responsibility for human rights compliance (anti-corruption), human resources, purchasing, corporate responsibility/CR and auditing. Responsibility always refers to our own employees and subcontractors.

In February 2019, the Executive Board and Supervisory Board published the annual Compliance Declaration pursuant to Section 161 of the German Stock Corporations Act (AktG). The declaration is fully reprinted in the HOCHTIEF Group Report 2018. We provide comprehensive information on our corporate governance practices online. At www.hochtief.com/corporate-governance, you will find our Code of Conduct, all past compliance declarations as well as the current Declaration on Corporate Governance pursuant to Sections 289f and 315d of the German Commercial Code (HGB).

Aspects of particular relevance to HOCHTIEF include complaint mechanisms, forced labor, child labor, discrimination, freedom of association, health and safety at work. Against this background, the various departments deal with the issues, evaluate risks, define measures and exchange information closely with each other on an ongoing basis. A working group with representatives of the specialist departments coordinates the joint procedure. The aim is to rule out human rights violations in all project work processes over which HOCHTIEF has an influence.

Respect for human rights along our supply chain is of central importance to us - our purchasing volume and thus also the procurement of services provided by third parties for HOCHTIEF corresponds to approximately two thirds of Group work done. This means that numerous people are directly or indirectly involved in our project work. Subcontractors and suppliers from countries with an increased risk of human rights violations are particularly examined by us. By adding human rights to the subject of supplier self-assessment - which we specifically evaluate - we ensure that potential contractual partners meet our human rights compliance requirements in their actions. We work exclusively with subcontractors and suppliers to whom this applies.

We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information about their businesses that EcoVadis analysts assess against sustainability criteria. The focus is on environment protection, employment rights and human rights, fair business practices, and the supply
chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.

Our project activities directly and indirectly involve large numbers of people. In this connection, we place special emphases on respect for human rights at every link in our supply chain. We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.

In addition to these checks, following delivery of goods or services, the HOCHTIEF project teams also conduct structured evaluations of our contract partners. This applies equally to both new and longstanding subcontractors and suppliers. In the HOCHTIEF Europe and Asia Pacific divisions, these in-project evaluations, which we perform both using established IT systems and manually, cover not only economic matters (such as the handling of change orders), but also environmental aspects
(such as the management of hazardous materials and waste and awareness of resource conservation)
as well as social issues (for instance, observing human rights, work safety directives, and fair pay).

We also set ourselves the goal of further improving transparency in our supply chain and of continuing to integrate sustainability aspects more strongly into our procurement processes. In the medium term, by 2030 at the latest, we wish to establish supplier and subcontractor CR performance as a quantifiable metric and a fixed selection criterion in prequalification.

In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.

At the present time, we see no significant risks likely to have a substantial negative impact on the sustainability aspect of human rights. Likewise, we currently anticipate no noteworthy risks arising from negative deviations from our major stakeholders’ expectations.

Further information can be found here and under the corresponding key performance indicators.

Using the Sustainability Code Declaration of Conformity in the sense of the „NAP Business and Human Rights“

1. Human rights policy statement

a. ) State whether your company has its own corporate guidelines for upholding human rights and whether they also encompass the ILO’s core labour standards.

b. ) Has the company management approved the policy statement?

c. ) Describe your company’s internal and external communication on the topic of human rights.

d. ) At which level is responsibility for human rights concerns enshrined? (CSR-RUG checklist 1b)

e. ) Define the reach that your guidelines have (which sites, including subsidiaries etc.).

a.) HOCHTIEF committed itself to the standards of the International Labor Organization (ILO) in 2000 and as a signatory to the UN Global Compact in 2008 to support and respect international human rights.

The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.

b.) In February 2019, the Executive Board and Supervisory Board published the annual Compliance Declaration pursuant to Section 161 of the German Stock Corporations Act (AktG). The declaration is fully reprinted in the HOCHTIEF Group Report 2018.

c.) We provide comprehensive information on our corporate governance practices online. At Corporate Governance - HOCHTIEF, you will find our Code of Conduct, all past compliance declarations as well as the current Declaration on Corporate Governance pursuant to Sections 289f and 315d of the German Commercial Code (HGB).

d.) HOCHTIEF sees key areas of responsibility for human rights compliance (anti-corruption), human resources, purchasing, corporate responsibility/CR and auditing. Responsibility always refers to our own employees and subcontractors.

e.) HOCHTIEF established the HOCHTIEF Code of Conduct in 2002, subject to ongoing review. It is binding for employees of HOCHTIEF Aktiengesellschaft and the HOCHTIEF Europe division. Available in 13 languages, it incorporates our compliance requirements. The same standards have been integrated into the codes of conduct for the companies in the HOCHTIEF Americas and HOCHTIEF Asia Pacific divisions.

2. Procedures for the identification of actual or potential adverse impact on human rights

a. ) State whether and how your company analyses human rights risks (caused by your business activities, your business relations, your products and services, at its sites, due to political parameters) (criterion 17, checklist aspect 4).

b. ) Are especially vulnerable groups of people incorporated into the risk assessment?

c. ) What is your company’s assessment of the human rights risks and its ability to counter these itself?

d. ) How are human rights risks incorporated into your company’s risk management?

a.) Aspects of particular relevance to HOCHTIEF include complaint mechanisms, forced labor, child labor, discrimination, freedom of association, health and safety at work. Against this background, the various departments deal with the issues, evaluate risks, define measures and exchange information closely with each other on an ongoing basis. A working group with representatives of the specialist departments coordinates the joint procedure. The aim is to rule out human rights violations in all project work processes over which HOCHTIEF has an influence.

b.) We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.


c.) At the present time, we see no significant risks likely to have a substantial negative impact on the sustainability aspect of human rights. Likewise, we currently anticipate no noteworthy risks arising from negative deviations from our major stakeholders’ expectations.

d.) In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.

3. Measures to review effectiveness / Element: grievance mechanism

a. ) Is there training for employees in the area of human rights?

b. ) State whether and how the upholding of human rights is checked.

c. ) Describe any internal grievance mechanisms and clearly assigned responsibilities within the company or explain how access to external grievance mechanisms is ensured.

d. ) Do whistle-blowing mechanisms also apply to suppliers?

a.) Based on the findings, suggestions for improvement were developed in consultation with the Executive Board and are now being implemented. Human rights will also be a special focus topic in future training courses to raise employees’ awareness for this issue.

b.) In order to identify potential sensitive areas for human rights violations at an early stage, HOCHTIEF has been using a "Quick Check on Human Rights" since 2017 in internal auditing projects. The results are processed by the relevant departments.

c.) As part of our grievance measures, HOCHTIEF’s whistleblower hotlines and official e-mail addresses can be used as a tool for reporting (possible) human rights violations. Due to its characteristics, these mechanisms are public and available to all our stakeholders, what allows us to prevent, mitigate and respond to possible human rights violations. The reporting options are presented on Compliance - HOCHTIEF.

d.) Outside stakeholders such as business partners and subcontractors are also able to report issues. HOCHTIEF publishes all contact channels for this purpose on the Group website.

4. Human rights due diligence obligations in the value chain

a. ) Is there a suppliers’ code of conduct that comprises the four ILO core labour standards?

b. ) State whether and how a check is performed for human rights risks prior to entering into a business partnership.

c. ) Are suppliers given training on human rights?

d. ) What processes does your company use to guarantee that its suppliers uphold human rights?

e. ) Do you implement measures (jointly with suppliers) in the event of a conflict or do you work with other stakeholders? If so, which ones?

f. ) What redress policies are there? Report on incidents in the reporting period.

a.) and b.)

The Group's expectations are laid down in the HOCHTIEF vision, corporate principles and codes of conduct. In principle, the HOCHTIEF Code of Conduct and HOCHTIEF Code of Conduct lay down a binding obligation for business partners to comply with human rights - this is also a contribution to risk management within the Group.

c.) We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information
about their businesses that EcoVadis analysts assess against sustainability criteria. The focus
is on environment protection, employment rights and human rights, fair business practices, and the supply chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.

d.) We began working with rating agency EcoVadis during process at HOCHTIEF the reporting year and plan to continue the relationship in the future. Subcontractors and suppliers provide information about their businesses that EcoVadis analysts assess against sustainability criteria. The focus is on environment protection, employment rights and human rights, fair business practices, and the supply
chain. If risks are identified, we work with the subcontractor or supplier concerned to develop specific measures (referred to internally as “corrective action plans”). In this way, we aim to further enhance sustainability and transparency in our supply chain.

Our project activities directly and indirectly involve large numbers of people. In this connection, we place special emphases on respect for human rights at every link in our supply chain. We apply special focus in screening potential suppliers and subcontractors from countries with heightened risk of human rights violations. To ensure that potential trading partners from such countries meet our standards in their conduct with regard to safeguarding human rights, we require suppliers to provide self-disclosure information, which we assess on a targeted basis.

In addition to these checks, following delivery of goods or services, the HOCHTIEF project teams also conduct structured evaluations of our contract partners. This applies equally to both new and longstanding subcontractors and suppliers. In the HOCHTIEF Europe and Asia Pacific divisions, these in-project evaluations, which we perform both using established IT systems and manually, cover not only economic matters (such as the handling of change orders), but also environmental aspects
(such as the management of hazardous materials and waste and awareness of resource conservation)
as well as social issues (for instance, observing human rights, work safety directives, and fair pay).
We also set ourselves the goal of further improving transparency in our supply chain and of continuing to integrate sustainability aspects more strongly into our procurement processes. In the medium term, by 2030 at the latest, we wish to establish supplier and subcontractor CR performance as a quantifiable metric and a fixed selection criterion in prequalification.

e.) and f.)

If contractual partners fail to meet our requirements and are given a negative assessment by our project teams, they are either provided with targeted support as part of our supplier development process—such as under the collaboration with EcoVadis—or are flagged in our system and no longer considered for future contracts. In that case, they are phased out of future selection processes, i. e. the business relationship ends.

Key Performance Indicators to criteria 17

Key Performance Indicator GRI SRS-412-3: Investment agreements subject to human rights screenings
The reporting organization shall report the following information:

a. Total number and percentage of significant investment agreements and contracts that include human rights clauses or that underwent human rights screening.

b. The definition used for ‘significant investment agreements’.

a. 100% according to the consent to the HOCHTIEF Code of Conduct: a) HOCHTIEF Code of Conduct (internal/own employees) and b) HOCHTIEF Code of Conduct for contractual partners (external)

b. In general, HOCHTIEF contracts are always based on the HOCHTIEF Code of Conduct and the HOCHTIEF Code of Conduct for contractual partners, respectively. 

Key Performance Indicator GRI SRS-412-1: Operations subject to human rights reviews
The reporting organization shall report the following information:

a. Total number and percentage of operations that have been subject to human rights reviews or human rights impact assessments, by country.

HOCHTIEF has deployed a human rights quick check in project audits by the internal audit function since 2017. 

- Via a risk analysis project on construction sites in Western Europe (Germany, Austria, Netherlands, Sweden, Denmark, Greece) in 2019, an evaluation for 9,74% of the Group employees was conducted.

- In 2018, CIMIC conducted a Human Rights Impact Assessment (HRIA) across the mining operations in Indonesia. In 2017, a comoarable assessment was conducted for activites in India. Thus, the assessments cover more than 38% of CIMIC staff. 

Key Performance Indicator GRI SRS-414-1: New suppliers subject to social screening
The reporting organization shall report the following information:

a. Percentage of new suppliers that were screened using social criteria.

97%
In each of our three divisions, we have established a prequalification process. When assessing potential contractual partners, we include information from supplier self-assessments as well as internal and external data (such as from rating agencies). By way of this process, new contractual partners are required to provide proof that their products and services meet our economic, ecological, and social requirements.

Key Performance Indicator GRI SRS-414-2: Social impacts in the supply chain
The reporting organization shall report the following information:

a. Number of suppliers assessed for social impacts.

b. Number of suppliers identified as having significant actual and potential negative social impacts.

c. Significant actual and potential negative social impacts identified in the supply chain.

d. Percentage of suppliers identified as having significant actual and potential negative social impacts with which improvements were agreed upon as a result of assessment.

e. Percentage of suppliers identified as having significant actual and potential negative social impacts with which relationships were terminated as a result of assessment, and why.

a. We have proactively conducted an assessment of potential human rights issues in the last 3 years. 1.99% of around 61.245 contractors and Tier 1 suppliers were assessed. 
b. Der total amount of parnters in the evaluation was 352. 
c. 28.83 % of total assessed where general risks (human rights) have been identified.
d. 100%
e. cf. d

18. Corporate Citizenship

The company discloses how it contributes to corporate citizenship in the regions in which it conducts its core business activities.

Value creation 2018

Value added analysis shows how HOCHTIEF generates added value while quantifying how the various public and private stakeholder groups benefit as a result.

In the 2018 reporting year, HOCHTIEF continued to rigorously pursue its strategic path in order to further increase profitability and liquidity. Sustainability in our activities resulted in a renewed listing in the Dow Jones Sustainability Index (DJSI). This commitment to sustainability further enhances our attractiveness to customers as well as on the capital and labor markets.

Net value added as a percentage of Group performance was 22.1% in 2018, above the prior-year level. The HOCHTIEF Group once again distributed the lion’s share of net value added in 2018 to employees, as in past years. This large proportion of value added means that we can continue offering attractive employment on fair terms. Distributions to minority shareholders accounted for EUR 177.5 million of value added in 2018. The increase relative to the prior year relates to the higher dividend.

At 4.9% (EUR 259.9 million), the proportion of value added distributed to public authorities in 2018 was slightly higher than in the prior year (4.7%).

See also Value creation 2018.

HOCHTIEF implements comprehensive risk management in all its divisions and operative units. Group-wide directives and standardized processes as for risk reporting are the basis to minimize risks in advance. Ecological and social risks are part of risk management as well. Through continuous monitoring and foresighted planning we are able to evaluate the short- and long-term effects of our project work and develop appropriate measures to avoid them. In 2018, no significant risks in relation to enviromental, social or employee-related issues have been identified, neither have there been any negative impacts on human rights or the fight against corruption from our company. Likewise we do not expect any risks due to negative deviations from the expectations of our key stakeholders.

Corporate citizenship at HOCHTIEF

As an international infrastructure group, HOCHTIEF shapes living spaces around the world and interacts closely with many people. We work with and for them and impact their daily lives. While the effects are usually positive, sometimes challenges are involved. We see ourselves as corporate citizens, and we embrace social and environmental responsibility wherever we work.

In this regard, the Group Directive on Donations and Sponsoring provided by Corporate Communications clearly defines focal areas for these activities, facilitates the efficient use of financial resources, and regulates responsibilities and reporting processes and secondly, designing and preserving living spaces. Corporate Communications, the department responsible, works with the Executive Board to define the strategic direction and is in charge of coordination. We support these causes through monetary donations, donations in kind, by contributing expertise, corporate volunteering, and personally committing time and effort to practical projects. No specific targets are set for these activities because we take our cues from immediate conditions and needs on the ground.

In 2018, the Group’s budget for donations and sponsorship totaled around EUR 5.1 million (2017: EUR 4.98 million).

We also promote the business locations of our construction projects. We prefer to work with local subcontractors and suppliers to secure jobs and sustainably strengthen economic development in the regions in which we operate. In 2018, we have awarded about 64.52 percent of our purchasing volume to contract partners from the regional catchment area throughout the Group.

We attach great importance to coordination among all parties involved. It is very important for HOCHTIEF that residents and commuters, clients, politicians, subcontractors, later users and other interested parties are always informed at an early stage. "Via Solutions Nord", led by HOCHTIEF, works closely with the Ministry of Transport. The site managers are in direct contact with journalists, residents and commuters and answer all questions.

Bridges to Prosperity

As part of the sponsorship focus “design and preservation of living spaces,” we support projects run by the NGO Bridges to Prosperity (B2P). > This collaboration revolves around the construction of pedestrian bridges in remote regions. The bridges give local residents a safe way to access education, health facilities, and markets—especially during the rainy season, when rivers often rise so dramatically that crossing them poses a serious danger. HOCHTIEF and its Group companies have been working with B2P since 2010. As regards the B2P projects, we intentionally get involved in regions
where we do not actively work. By helping to improve people’s connections to other areas, we enable them to participate in economic development on both national and local levels. Improved access to educational institutions is especially important in boosting the potential for economic success—and it translates into better prospects for young people. According to B2P estimates, household incomes in areas that gain regular access to markets rise by an average of 30%.

Further information can be found in the Group Report starting on page 134.

Key Performance Indicators to criteria 18

Key Performance Indicator GRI SRS-201-1: Direct economic value generated and distributed
The reporting organization shall report the following information:

a. Direct economic value generated and distributed (EVG&D) on an accruals basis, including the basic components for the organization’s global operations as listed below. If data are presented on a cash basis, report the justification for this decision in addition to reporting the following basic components:
i. Direct economic value generated: revenues;
ii. Economic value distributed: operating costs, employee wages and benefits, payments to providers of capital, payments to government by country, and community investments;
iii. Economic value retained: ‘direct economic value generated’ less ‘economic value distributed’.

b. Where significant, report EVG&D separately at country, regional, or market levels, and the criteria used for defining significance.

a. Net value added 2018: 5,315.3 million Euro
i. Sales 2018: 23,882.3 million Euro
ii.Distribution of value added: 
--> to employees: 4,176.1 Mio. Euro (78.6%)
--> to lenders: 160.8 Mio. Euro (3.0%)
--> to minority shareholders: 177.5 Mio. Euro (3.3%)
--> to public authorities: 259.9 Mio. Euro (4.9%)
--> to shareholders: 410.1 Mio Euro (7.7%)
--> to company: 410.1 Mio. Euro (2.5%)
--> to company and shareholders: 541.1 (10.2%)

Please see value creation overview including corresponding distribution on the following HOCHTIEF webpage: http://www.hochtief.com/hochtief_en/175.jhtml

19. Political Influence

All significant input relating to legislative procedures, all entries in lobby lists, all significant payments of membership fees, all contributions to governments as well as all donations to political parties and politicians should be disclosed by country in a differentiated way.

HOCHTIEF organizational units and companies make no direct or indirect donations to political organizations, parties or individual politicians. (Excerpt from our Code of Conduct. You can find the detailed Code of Conduct here).

Contributions and memberships within the Group are centrally reported and reviewed on a regular basis. A list of current memberships is available from the website: http://hochtief.com/hochtief_en/3730.jhtml

HOCHTIEF is committed to sustainability in many ways. With clear commitments and memberships in sustainability and other organisations, we are committed to guidelines and standards and document our commitment to the outside world. HOCHTIEF is a participant in the UN Global Compact and submits an annual progress report. As a long-standing member of organisations such as Transparency International, DGNB, Green Building Council of Australia and B.A.U.M., we support the work of these organisations.

In 2018, HOCHTIEF was listed in the Dow Jones Sustainability Index for the thirteenth time in a row and in the CDP for the tenth time. We have achieved above-average results in some cases for both internationally renowned valuations. It also participates in other ratings.

Legislative process

All legislative procedures are relevant to us and are taken into account by HOCHTIEF. Pursuant to the General Data Protection Regulation (EU GDPR), which came into effect in the reporting year, HOCHTIEF has taken not only comprehensive measures to protect personal data but also precautions concerning data exchanges in order to meet the new requirements.


Criteria for HOCHTIEF's commitment

Contributions are managed locally and in accordance with the HOCHTIEF rules. As already mentioned above, HOCHTIEF organizational units and companies make no direct or indirect donations to political organizations, parties or individual politicians. HOCHTIEF has spent 0,00 EUR on direct political contributions in 2018.

All further decisions on our social commitment are based on HOCHTIEF's basic principles and guidelines.

Detailed information on our compliance management can be found under criterion 20 "Compliance with laws and guidelines" and the key performance indicators (20).

Key Performance Indicators to criteria 19

Key Performance Indicator GRI SRS-415-1: Political contributions
The reporting organization shall report the following information:

a. Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary.

b. If applicable, how the monetary value of in-kind contributions was estimated.

0 € (HOCHTIEF organizational units and companies make no direct or indirect donations to political organizations, parties or individual politicians.)

20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

Compliance

Compliance is an integral component of our corporate principles. We expect our employees to comply with HOCHTIEF's vision and the Code of Conduct in their day-to-day work. These rules apply in all HOCHTIEF companies and are an integral part of our corporate culture. The Codes of Conduct contain important legal provisions and requirements from the voluntary commitment declarations to which we have committed ourselves (e.g. UN Global Compact, ILO Core Labour Standards).

The HOCHTIEF Code of Conduct is binding for employees of HOCHTIEF Aktiengesellschaft and the HOCHTIEF Europe division. The companies of the HOCHTIEF Americas and Asia Pacific divisions have adopted these standards in their codes of conduct. The HOCHTIEF Code of Conduct helps employees to act correctly in areas such as antitrust issues, conduct towards business partners and potential conflicts of interest. It also provides assistance in identifying bribery or corruption, in dealing with donations and sponsorship funds, and in dealing with certain information immanent to internal knowledge, confidentiality or data protection.
It also covers the following areas: Health and environmental protection, company assets including the documentation of business transactions, dealing with company property and assets or insider rules as well as principles of social responsibility concerning respect for human dignity, the rejection of child and forced labour, upholding equal opportunities and bans on discrimination, the right to organize, and the right to collective bargaining.

Compliance Organization

The Compliance System is headed by the Chairman of the Executive Board of HOCHTIEF Aktiengesellschaft. The Chief Compliance Officer reports annually to the Audit Committee of the Supervisory Board. In performing its duties, it receives support from Group compliance and law, among other things. All divisions have similar organizational structures. The Compliance Officers in the divisions head the respective compliance organizations. You report directly to the Chief Compliance Officer. Their tasks include implementing HOCHTIEF's compliance program, identifying compliance risks at an early stage and taking appropriate countermeasures. As local contacts for employees in the companies of the divisions, the Compliance Managers support the implementation and further development of the compliance system.

A Compliance Committee is established in each HOCHTIEF division and meets at least once a quarter under the leadership of the Compliance Officer. The Compliance Committees are composed of the division's Compliance Officer, representatives of the operational business and individual specialist departments such as Human Resources, Internal Audit or Purchasing. The task of the Compliance Committees is to support the compliance organization in implementing the compliance program and integrating compliance into business processes and procedures to advise and support you.

Our compliance system is designed to prevent compliance violations (prevention). The compliance organization focuses on preventing corruption and antitrust violations. To prevent compliance violations in other areas, the respective specialist functions are responsible.

The HOCHTIEF compliance program

Our aim is to establish good, successful, long-term business relationships. Accordingly, we conduct
due-diligence reviews before entering into business transactions. For example, the compliance organization screens joint venture partners and consultants in a precisely defined selection procedure and approves signing subject to integrity criteria. We also check potential partners for integrity and reliability, making use of external databases as needed. This business partner compliance due diligence process is fully documented.

We keep employees informed about the compliance program, points of contact, and internal directives via the customary in-house media. Our training programs are available on the corporate intranet. Among other things, 2018 saw the launch of an e-learning program on the HOCHTIEF Code of Conduct for all employees.

In 2018, a total of 38,725 employees in Germany and internationally took part in training provided by Compliance— this corresponds to a share of almost 70% of employees within the Group. The figure comprised 23,837 employees in the HOCHTIEF Asia Pacific division, 10,689 employees in the HOCHTIEF Americas division, and 4,209 employees in the HOCHTIEF Europe division (including the holding company).

By 2020, we want all HOCHTIEF employees to complete at least one compliance training course. Another
aim is to provide our employees with maximum security in dealing with competitors.

We require all HOCHTIEF employees to report any suspected compliance violations. Various channels
are provided for this purpose. If employees do not wish to go directly to their direct superior, they can use
whistleblower systems that are in place in all divisions. Both hotlines and e-mail addresses are available. All reports are escalated to compliance officers or Corporate Compliance. To protect whistleblowers, reports can be rendered anonymous on request.


Opportunity and risk situation in the HOCHTIEF Group: Compliance
The aim of our compliance system is to prevent corruption and antitrust infringements from the outset.
This is put into effect through regular workforce training as well as the adoption of suitable processes and systematic controls. It is thus the job of the compliance organization to put organizational precautions in place so as to secure compliance with prevailing law on the part of the company, its decision-making bodies, and the workforce.
We therefore rate the risks in connection with compliance as low.


HOCHTIEF’s whistleblower system

We require all HOCHTIEF employees to report any suspected compliance violations. Various channels
are provided for this purpose. If employees do not wish to go directly to their direct superior, they can use
whistleblower systems that are in place in all divisions. Both hotlines and e-mail addresses are available. All reports are escalated to compliance officers or Corporate Compliance. To protect whistleblowers, reports can be rendered anonymous on request.


Detailed information can be found in the Group Report starting on page 80.

Key Performance Indicators to criteria 20

Key Performance Indicator GRI SRS-205-1: Operations assesed for risks related to corruption
The reporting organization shall report the following information:

a. Total number and percentage of operations assessed for risks related to corruption.

b. Significant risks related to corruption identified through the risk assessment.

a.
According to Transparency International's Corruption Perception Index (CPI), HOCHTIEF mainly has fully consolidated subsidiaries and associates in countries with low or very low risk of corruption(CPI 100-75: 267 HOCHTIEF subsidiaries and associates; CPI 74-50: 105 HOCHTIEF subsidiaries and associates; CPI 49-25: 48 HOCHTIEF subsidiaries and associates; CPI 24-0: 3 HOCHTIEFsubsidiaries and associates).

A graphical overview of the number of HOCHTIEF subsidiaries and associates with regard to the risk of corruption in their respective countries can be found here.

If a violation of compliance rules is suspected, Corporate Compliance or Corporate Auditing initiates compliance checks. Auditing also monitors adherence to compliance processes and the corresponding directives. Checks were made in 64 instances during 2018.

HOCHTIEF is committed to the UN conventions and was also the first construction company in the world to commit to ILO standards in 2000.

b. We rate the risks in connection with compliance as low.

Key Performance Indicator GRI SRS-205-3: Incidents of corruption
Die berichtende Organisation muss über folgende Informationen berichten:

a. Total number and nature of confirmed incidents of corruption.

b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.

c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.

d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

Regarding the subject of combating corruption, please refer to the comprehensive comments on the HOCHTIEF compliance system under criterion 20 of the Declaration of Conformity. We refrain from reporting cases of corruption, as there is no obligation to provide information.

Key Performance Indicator GRI SRS-419-1: Non-compliance with laws and regulations
The reporting organization shall report the following information:

a. Significant fines and non-monetary sanctions for non-compliance with laws and/or regulations in the social and economic area in terms of:
i. total monetary value of significant fines;
ii. total number of non-monetary sanctions;
iii. cases brought through dispute resolution mechanisms.

b. If the organization has not identified any non-compliance with laws and/or regulations, a brief statement of this fact is sufficient.

c. The context against which significant fines and non-monetary sanctions were incurred.

If a violation of compliance rules is suspected, Corporate Compliance or Corporate Auditing initiates compliance checks. Auditing also monitors adherence to compliance processes and the corresponding directives. Checks were made in 64 instances during 2018. The Compliance organization also regularly asks about adherence to compliance rules in self-assessments and interviews. A compliance spot check is additionally held once annually in the HOCHTIEF Europe division to show the importance of compliance in day-to-day activities. In 2018, the compliance spot check was integrated into the Europe-wide employee survey, which addresses the following compliance issues: the general perception of compliance within the Group, responsibility for compliance, reporting of suspected compliance violations, and the potential consequences of violations. Great importance is also attached to implementing Compliance in the companies of the HOCHTIEF Americas and HOCHTIEF Asia Pacific divisions.

Corporate Compliance and Corporate Auditing also cooperate in compliance audits for HOCHTIEF projects, in which adherence to compliance requirements is assessed on-site against a risk matrix. Additionally, Corporate Auditing conducts quick checks on projects to analyze compliance conduct and respect of human rights for early identification of potential risks.

In 2018, no significant monetary fines were imposed on HOCHTIEF due to infringement of environmental laws.The internal reporting limit is EUR 10,000.