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.
ComplianceCompliance 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 OrganizationThe 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.