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 ├╝ber 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.