voestalpine requires that all of its companies and its employees in all countries, where voestalpine operates, comply with all laws. This is explicitly stated in the Code of Conduct. voestalpine like- wise requires that its suppliers fully comply with all applicable laws in their respective countries. This regulation also applies to international sanctions or sanctions imposed by the European Union. For voestalpine, however, compliance is more than merely acting in accordance with the laws. It is the expression of a corporate culture built on ethical and moral principles.
Since December 2011, voestalpine has no longer supplied products to Syria and Iran (existing contracts are still being fulfilled until they expire). Prior to December 2011, only those products were supplied to these countries that did not fall under the UN sanctions.
Code of Conduct
The voestalpine Code of Conduct was set forth in written form in 2009. It is based on the Group’s corporate values and provides the foundation for ethically and legally sound conduct by all of the Group’s employees. The Code of Conduct is also directed to voestalpine customers, suppliers, and other business partners.
The Code of Conduct is available in German, English, and eleven additional languages and can be downloaded from the company website:
The Code of Conduct covers the following areas:
- Compliance with laws and other external and internal regulations
- Fair competition
- Corruption, bribery, and acceptance of gifts
- Respect and integrity
- Conflicts of interest
- Handling of corporate information/confidentiality
- Corporate communications
- Use of the Internet and IT
- Insider information
- Reporting of misconduct
The Code of Conduct is binding for all members of the Management Board, managing directors, and employees of all companies in which voestalpine AG has a direct or indirect stake of at least 50% or which it controls in any other way. With regard to all other companies, in which voestalpine AG has a direct or indirect stake of at least 25%, but which it does not control, the Code of Conduct is brought to their attention and they are requested to enforce it by way of independent recognition thereof by their decision-making bodies that are governed by corporate law. In the event of a violation against statutory provisions, internal guidelines, regulations, and directives or against provisions of the voestalpine Code of Conduct, employees will be subject to disciplinary measures. Furthermore, violations can have consequences under criminal and/or civil law, e.g., recourse claims and claims for compensatory damages.
voestalpine is pursuing the goal of having the Code of Conduct applied throughout its sphere of influence. Suppliers and consultants are required to comply with the Code of Conduct for Business Partners. Additionally, Group companies are urged to bring the Code of Conduct to the attention of their customers and to strongly encourage them to commit to compliance therewith. All of voestalpine’s business partners are also requested to promote compliance with the Code of Conduct among their own business partners along the entire supply chain.
voestalpine AG has adopted the following Group guidelines to serve as a helpful tool in applying the Code of Conduct:
Business conduct
This guideline is an expansion and concretization of the Code of Conduct with regard to the subjects of corruption/bribery/acceptance of gifts and conflicts of interest and regulate, for example, permissibility of gifts, invitations and other benefits, donations, sponsoring, ancillary activities, and the private purchase of goods and services by employees of customers and suppliers.
Dealings with business intermediaries/brokers and consultants
This guideline is an expansion and concretization of the Code of Conduct with regard to the subjects of corruption/bribery/acceptance of gifts. They define the procedure to be complied with prior to contracting or engaging sales representatives, representatives, or other sales consultants. An objective analysis of the prospective business partner’s business environment and scope of activities prior to establishing business relations is required to ensure that the business partner can comply with all applicable laws and the voestalpine Code of Conduct.
As is the case with the Code of Conduct, these guidelines also apply to all members of the Management Board, managing directors, and employees of the voestalpine Group as defined above.
Human rights
voestalpine is committed to respecting and upholding human rights throughout the Group; should any violations occur in this regard, Group management would react promptly. All voestalpine suppliers must sign the Code of Conduct for Business Partners, which stipulates respecting and upholding human rights as mandatory. Customers are also strongly requested to respect and uphold human rights.
Child and forced labor
Child and forced labor are not tolerated. There are no known cases of child labor or forced/compulsory labor across the Group. The Code of Conduct for Business Partners obliges suppliers explicitly to comply with the prohibition of child and forced labor.
Rights of indigenous peoples
voestalpine and its facilities operate solely in developed industrial regions; therefore, the rights of aboriginal peoples are not restricted in any way by voestalpine’s business operations.
Human rights training
Worldwide security personnel attached to plant security services is comprised largely of voestalpine employees. All of these employees receive training regarding compliance with human rights. Security personnel that is provided by external contractors must commit to compliance with the Code of Conduct and therefore to compliance with human rights. The respective employers of this security personnel are responsible for their training.
Collective bargaining and the right to freedom of association
Collective agreements are applied in all employment agreements in countries where such agreements exist. Around 80 % of the voestalpine workforce is in an employment relationship that is regulated by a collective agreement. At all voestalpine locations, each employee has the fundamental right and freedom to become a member of a union; works councils can be set up at all voestalpine locations. There is a Group Works Council and a European Works Council in the voestalpine Group. Traditionally, the voestalpine management places great value on maintaining a good basis for communication with the unions and the members of the Works Councils.
Compliance system
The management of the respective Group company is responsible for adherence to the compliance regulations. A compliance system was put in place in the voestalpine Group during the business year 2011/12 to support management in meeting this responsibility and to set up the necessary processes.
In addition to a Group compliance officer, a compliance officer was appointed in each division; furthermore, additional compliance officers were appointed in certain divisional sub-units.
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.
The compliance officers are responsible for the following areas:
- Antitrust law
- Corruption
- Capital market compliance
- Fraud (internal cases of theft, fraud, embezzlement, or breach of trust)
- Conflicts of interest
- Special issues that are assigned to the compliance officers by the Management Board of voestalpine AG (e.g., in connection with UN or EU sanctions)
All other compliance issues, e.g., environmental law, taxes, accounting, labor law, protection of employees, or data protection and privacy are not part of the compliance officer’s area of responsibility. These compliance issues are handled by the respective specialist departments.
Preventive measures
Within the scope of its compliance efforts, voestalpine places particular importance on preventive measures, including training and communication. Since 2002, managing directors, sales personnel, and other employees have undergone face-to-face training with regard to antitrust law.
In 2009, more than 4,500 voestalpine Group employees received training on this issue in e-learn-ing courses; in 2012, the same employees completed a refresher course. Additionally, in the business year 2012/13, an online course on the Code of Conduct was rolled out Group-wide. This training focused on compliance with the law and internal guidelines as well as corruption and antitrust law. Around 18,000 employees have participated in this training.
Compliance training is mandatory for young executives: there are six to seven training sessions each year for around 20 employees.
In addition to e-learning courses, there is also face-to-face instruction on the issues of antitrust law and corruption, especially for sales employees. Face-to-face training is also provided for capital market compliance issues, primarily for voestalpine AG employees.
Furthermore, compliance is a regular topic in Group communications and is often mentioned– including by top management–at major employee events at both the Group and the divisional level.
Reporting of compliance violations
Reports of compliance violations should be primarily made openly, that is, providing the whistleblower’s name. According to the Code of Conduct, such reports can be made to the direct supervisor, the appropriate legal or HR department, management of the respective Group company, the audit department of voestalpine AG, or one of the Group’s compliance offices. Upon request, whistleblowers are ensured of absolute confidentiality.
In 2012, a web-based whistleblower system was launched that enables employees to file anonymous reports about violations. Reports using this system can be made in the areas of antitrust law, corruption, fraud, and conflicts of interest, in other words, only reports on these issues are processed through this system. The system enables compliance officers to communicate with whistleblowers while maintaining absolute anonymity.