A new, comprehensive compliance management system encompassing risk analysis/prevention and identification/reaction was established in the voestalpine Group during the business year 2011/12, thus placing Compliance on a very broad groupwide basis. In addition to a Group Compliance Officer, additional compliance officers were appointed for all divisions and a number of business units as well as larger Group companies. The Group Compliance Officer reports directly to the Chairman of the Management Board and is not bound by instructions.
The Compliance organization is responsible for the following areas:
- Antitrust law;
- Capital market compliance;
- Fraud (internal cases of theft, fraud, embezzlement, breach of trust);
- Conflicts of interest; and
- Special issues that are assigned to the compliance officers by the Management Board of voestalpine AG (e.g. UN or EU sanctions).
All other compliance issues—such as those relating to the environment, taxes, accounting, labor law, employee protection, data protection and privacy, etc.—do not fall within the responsibility of the compliance officers and/or are not covered by Compliance. In this regard, the responsibility for compliance management rests with the respective specialist department.