The A1 Telekom Austria Group acts with honesty, fairness andtransparency to secure its economic success and reputation inthe long term. The compliance management system provides aframework for acting in a responsible manner.
For the A1 Telekom Austria Group, achieving the defined business goals is not theonly thing that matters — how it goes about doing so is also essential. The over-riding principle is acting with integrity and responsibility towards its employees,customers, shareholders, external creditors and the public.
Prevention and reaction
The A1 Telekom Austria Group owes it to all of its stakeholders to ensure that itsstandards of integrity are realised as a key component of its corporate culture.Acting with honesty, fairness and transparency is the only way to secure theGroup’s economic success and reputation in the long term.
To achieve this, the A1 Telekom Austria Group has a sophisticated compliancemanagement system based on the central elements of prevention and reaction.To prevent potential misconduct, the Group has established clear rules for actingethically and with integrity in all business relationships, and integrated appropri-ate controls within its business processes.
To enable an appropriate response to potential misconduct, indications and evi-dence are collected via a dedicated portal and addressed in strict confidentialityas part of a structured process. This allows the remediation of any weaknessesand the continuous improvement of the compliance management system.
A scoping process has identified the following areas as key compliance topics:corruption prevention and integrity, antitrust law, data protection and capitalmarket compliance. Group Compliance ensures the consistent implementation ofthe corresponding measures and instruments at all business units with thesupport of the local compliance managers at the subsidiaries. The A1 TelekomAustria Group’s compliance management system is consistent with the interna-tionally recognised standards issued by Transparency International and InstitutDeutscher Wirtschaftsprüfer (Institute of Public Auditors in Germany). This wasconfirmed by an independent auditor in 2013. Furthermore, the essential ele-ments of the compliance management system were successfully reviewed foreffectiveness in 2016 and 2017 throughout the whole company by GroupInternal Audit and Group Compliance.
Acting with integrity and responsibility
The Code of Conduct is a central instrument in the A1 Telekom Austria Group’scompliance management system. It is aimed at all employees and the entiremanagement team and is intended to help foster ethically and legally impeccableconduct in the various decisions that have to be taken every single day. It con-tains advice and regulations on fair conduct, gifts and personal benefits, confi-dentiality, conflicts of interest, protecting company assets, indications of viola-tions, communicating the content of the Code of Conduct, and the Group’swhistleblowing principles. In 2017, the Code of Conduct was revised andbrought into line with the Guiding Principles ‘Team, Trust and Agility’ that applythroughout the Group to aid the embodiment of the corporate culture (see‘Employees’).
This is supplemented by group-wide guidelines providing detailed assistance onconcrete topics, such as anti-corruption and conflicts of interest, capital marketcompliance and antitrust law. ISO standards for compliance management sys-tems (ISO 19600) and anti-corruption management systems (ISO 37001) havebeen factored into the ‘anti-corruption and conflicts of interest’ guidelines.
Target-group-optimised training sessions on compliance issues take place on aregular basis to ensure that the principle of integrity is anchored throughout thecompany in a sustainable manner. Online training was prioritised in 2017. The top-ics of anti-corruption, integrity, data protection, information security, antitrust lawand capital market compliance were explained in a practical way in a number ofmandatory group-wide e-learning modules. Around 3,500 employees and man-agers were also trained in compliance classroom training in 2017. To clarify anyquestions they may have, A1 Telekom Austria Group employees can also contactthe ‘ask.me’ compliance helpdesk, which dealt with around 450 questions in 2017.
A matter of corporate culture
Systematic adherence to all rules and regulations in the course of the company’sday-to-day work makes compliance a central element of the corporate culture.Key factors include, not least, the example set by senior management and the re-sponsibility of all employees for their own actions. Employees and third partiescan use the ‘tell.me’ whistleblower platform to anonymously report informationon potential misconduct in order to sustainably prevent and identify potentialrisks within the A1 Telekom Austria Group. In 2017, approximately 40 relevanttips were submitted via this compliance instrument and carefully investigated.
The A1 Telekom Austria Group responds to incidents with appropriate sanctions.If an actual case of misconduct is established, the potential consequences rangefrom educational measures and process improvements via reprimands throughto dismissals or the termination of business relationships. ▬
Issues andinstruments in thecompliancemanagementsystem
Continuous improvement / audit / certification
Compliance / management reporting
Culture and attitude
Compliance management system
In 2017, the A1 Telekom Austria Group won thefirst-ever Austrian Compliance Award in the cat-egory ‘Excellence in Compliance Culture’ andwas recognised for the third time for its innova-tive compliance communications, after having re-ceived the European Change CommunicationAward in 2012 and the Communication Excel-lence Award in 2013. The jury was particularlyimpressed by the Group’s use of innovative com-munication methods, such as an internal socialmedia platform, for agile communication andpromotion of the compliance culture.