In the business year 2011/12, a new, comprehensive compliance management system was established, based on risk analysis/prevention, detection and reaction, and compliance efforts were undertaken on a very broad Group-wide basis. In addition to a Group compliance officer, a compliance officer was appointed for each division, and for a series 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 directives. The compliance organization is responsible for the following areas:
- Antitrust law,
- Corruption,
- Capital market compliance,
- Fraud (internal incidences of theft, fraud,
- embezzlement, breach of trust),
- Conflicts of interest and
- Special issues with which the compliance offers are assigned by the Management Board of voestalpine AG (e.g., UN or EU sanctions).
All other compliance issues, such as those relating to environment, tax, invoicing, employment law, employee protection, data protection, etc., do not fall within the responsibility of the compliance officer and are not included in the compliance function. In these cases, responsibility for compliance management lies with each specialist function.
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