Business Compliance

FAIR COMPETITION



The avoidance of corruption and anti-competitive behaviour has become an important management responsibility in recent years. The potential damage that a company may incur because of corrupt or anti-competitive behaviour on the part of individual employees can at times reach drastic proportions.

Even if STRABAG generates much of its revenue in countries with a low risk of corruption, in places like Germany, Austria and Poland, the international nature of its business means that some activities are also performed in countries with a higher corruption risk as measured, for example, by the Corruption Perceptions Index¹. Transparent behaviour to minimise risk is required in all regions, especially during contract award or in negotiations with partner companies and subcontractors.

STRABAG acted in 2008 by implementing a Compliance Management System (CMS) and has been continuously developing it ever since. The purpose of the CMS is to prevent violations of the law and any resulting material and immaterial damage, and to maintain the company’s good reputation as a business partner, contractor and employer.

Projects and initiatives

Working together with an external consulting company and the group’s internal legal department, STRABAG SE developed a certifiable Business Compliance Management System (BCMS) in line with ISO 19600 (Compliance Management Systems) and ISO 37001 (Anti-Bribery Management Systems).
As of 2020, the new BCMS replaces the previous Business Compliance Guidelines and Business Compliance Guidelines for Business Partners and consists of the following documents:

• BCMS description
• Management Directive on the Avoidance of Corruption and White-Collar Crime
• Management Directive on Business Partner Assessments
• Management Directive on Cartel and Competition Law
• Management Directive on Conflicts of Interest
• Supplier Code of Conduct
• Business Compliance Risk Analysis

• Number of management employees trained in 2019
  - Classroom course “Avoidance of Corruption and Anti-Competitive Violations”
  Total: 309 (2018: 75)
  Target: 400 people/year over a three-year average

- Classroom course “Competition Law” Target:
Total: 350 (2018: 522)
Target: 400 people/year over a three-year average

• Number of business compliance violations discovered in the year (violations are assigned to the year in which they were conclusively discovered): 2 (2018: 2)