Since its IPO in 1995, the voestalpine Group has continued to expand its compliance activities in order to protect the company against financial damages and prevent damage to its reputation. Initially, within the scope of the IPO, the focus was on capital market compliance, with additional compliance issues being added subsequently. Since 2002, trainings in antitrust law have been held in all of the Group’s divisions on a regular basis. A major step was the introduction of a Code of Conduct in 2009, which is valid for all of the Group’s employees.
In the business year 2011/12, a new, comprehensive compliance structure was set up in the voestalpine Group. In addition to the Group compliance officer, divisional compliance officers were appointed in all of the divisions. The Group compliance officer reports directly to the Chairman of the Management Board and is independent and not bound by directives. The divisional compliance officers report to the Group compliance officer and to the respective heads of the divisions.
Once the new compliance structure was introduced, the Management Board of voestalpine AG also adopted a number of compilations of Compliance Rules and Regulations. The basic objective and the compliance strategy are set forth in the Compliance Manual. The Business Conduct Guideline as well as the guideline regarding dealings with business intermediaries/brokers and consultants supplement and define the Code of Conduct more closely, especially with regard to the subject of corruption.
Furthermore, in the past business year, a web-based whistleblower system was launched that enables employees to file anonymous reports about violations in the areas covered by compliance regulations—antitrust law, corruption, fraud, and conflicts of interest. This will enable systematic use of internal information to effectively uncover compliance risks within the company early on.
The top priority of the activities of the compliance officers are preventive measures. In this context, comprehensive training programs have been carried out in all of the Group’s units. In order to achieve a training effect that is as broad-based as possible, e-learning systems are being increasingly used. For example, more than 4,500 Group employees participated in an Internet-based e-learning course on antitrust law, including a final test. Such e-learning courses will be used more and more in the future for training purposes. Compliance training has been provided for years within the scope of executive training programs. Regular communication measures are used to bring compliance issues to the attention of our employees, particularly at major Group and divisional events.