Compliance

For the A1 Telekom Austria Group, achieving the defined business goals is not the only 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 its standards of integrity are realised as a key component of its corporate culture. Acting with honesty, fairness and transparency is the only way to secure the Group’s economic success and reputation in the long term.

To achieve this, the A1 Telekom Austria Group has a sophisticated compliance management system based on the central elements of prevention and reaction. To prevent potential misconduct, the Group has established clear rules for acting ethically 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 confidentiality as part of a structured process. This allows the remediation of any weaknesses and 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 capital market compliance. Group Compliance ensures the consistent implementation of the corresponding measures and instruments at all business units with the support of the local compliance managers at the subsidiaries. The A1 Telekom Austria Group’s compliance management system is consistent with the interna- tionally recognised standards issued by Transparency International and Institut Deutscher Wirtschaftsprüfer (Institute of Public Auditors in Germany). This was confirmed by an independent auditor in 2013. Furthermore, the essential ele- ments of the compliance management system were successfully reviewed for effectiveness in 2016 and 2017 throughout the whole company by Group Internal Audit and Group Compliance.

Acting with integrity and responsibility

The Code of Conduct is a central instrument in the A1 Telekom Austria Group’s compliance management system. It is aimed at all employees and the entire management team and is intended to help foster ethically and legally impeccable conduct 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’s whistleblowing principles. In 2017, the Code of Conduct was revised and brought into line with the Guiding Principles ‘Team, Trust and Agility’ that apply throughout the Group to aid the embodiment of the corporate culture (see ‘Employees’).

This is supplemented by group-wide guidelines providing detailed assistance on concrete topics, such as anti-corruption and conflicts of interest, capital market compliance and antitrust law. ISO standards for compliance management sys- tems (ISO 19600) and anti-corruption management systems (ISO 37001) have been factored into the ‘anti-corruption and conflicts of interest’ guidelines.

Target-group-optimised training sessions on compliance issues take place on a regular basis to ensure that the principle of integrity is anchored throughout the company in a sustainable manner. Online training was prioritised in 2017. The top- ics of anti-corruption, integrity, data protection, information security, antitrust law and capital market compliance were explained in a practical way in a number of mandatory group-wide e-learning modules. Around 3,500 employees and man- agers were also trained in compliance classroom training in 2017. To clarify any questions they may have, A1 Telekom Austria Group employees can also contact the ‘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’s day-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 parties can use the ‘tell.me’ whistleblower platform to anonymously report information on potential misconduct in order to sustainably prevent and identify potential risks within the A1 Telekom Austria Group. In 2017, approximately 40 relevant tips 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 range from educational measures and process improvements via reprimands through to dismissals or the termination of business relationships. ▬