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, Group-wide basis. In addition to a Group Compliance Officer, additional Compliance officers have been 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, but is not bound by instructions.
The Compliance organization is responsible for the following areas:
- Antitrust law;
- Compliance with capital market regulations;
- 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—e.g., environmental law, taxes, accounting, labor law, protection of employees or data—are not part of the Compliance officers’ sphere of responsibility. These Compliance issues are handled by other organizational units.