Compliance and Anti-Corruption at Energie AG Oberösterreich

Energie AG’s compliance and anti-corruption goals are:

• To ensure compliance with laws, regulations, and all Group-wide guidelines and standards
• To prevent property damage and reputational damage
• To minimise/avoid liability risks and non-material damage
• To raise awareness among all Energie AG employees of compliance with guidelines and the Code of Conduct
• To promote a fully applied and consistent compliance culture
• To implement effective prevention measures
• To improve legal certainty
• To ensure a values-conscious organisation culture
• To ensure fair competition

Compliance at Energie AG is based on a mutual understanding of values which is expressed in the Code of Conduct “This is how we think; this is how we act” and published for all stakeholders on the website.

The Code of Conduct is the key element that supports action in compliance with laws and guidelines. It is the foundation for all business activities and decisions at the Energie AG Group. It is the basis for moral, ethical and legally sound behaviour on the part of all Group employees. The Code of Conduct is mandatory for all parties.

To establish compliance effectively throughout the Group of companies, a compliance management system was established, appropriate guidelines were authored and numerous face-to-face training sessions were held in recent years. The content, responsibilities, distributions of skills, and required documentation and reporting have all been decided. Thanks to an interactive e-learning tool, staff have the ideal opportunity to harmonise their need for information with their daily working life. All managers and employees throughout the Group have been and will continue to be informed about the in-house Code of Conduct.

The experts in the various areas of legal specialism monitor the relevant national and European legislative frameworks. The Compliance Organisation is involved in issues relevant to the Group as a whole.

Compliance Forum

The Compliance Forum was set up to ensure consistent compliance rules. Regular meetings help to ensure the necessary exchange of information and consistent treatment of compliance-related matters throughout the Group. All areas of the Group have the opportunity to submit compliance queries and receive compliance advice.

Promoting a Compliance-Conscious Culture

Management are responsible for promoting a compliance-conscious culture among staff. Energie AG ensures that employees know our compliance values and put them into practice. The Group Management Board agreed measurable and adjustable compliance goals with management staff during the 2017/2018 fiscal year.

Anti-Corruption

Energie AG’s entities and employees are subject to provisions regarding public officials (Amtsträger) within corruption law. There are comprehensive compliance standards in force at the Energie AG Group to prevent corruption. Training courses to this effect are provided on an ongoing, Group-wide basis. The “Anti-Corruption” learning module offered in Austria has so far been completed by 72% of our employees in the country.

There were no incidents of corruption in the Energie AG Group in the 2017/2018 fiscal year.

Antitrust Compliance

Energie AG unconditionally declares its commitment to fair competition with its competitors, business partners and other market participants. For this reason, Group-wide training courses on antitrust law were held and the existing antitrust manual was updated. With its comments on the necessary market behaviour, the manual is primarily aimed at the sales-oriented divisions and is also available to all employees in the Energie AG Group via the Intranet.

Respect for Human Rights

Respect for human rights is a natural part of life for the Energie AG Group. We expect all our business partners to join us in adhering to the statutory framework, along with the applicable laws and standards on human rights. In terms of respect for human rights, we cannot discern any material risks for compliance with the applicable legal standards in Europe. Risks in the earlier links of the supply chain cannot be entirely ruled out. For this reason, we exercise due diligence in procurement.

Energie AG does not tolerate any discriminatory conduct or unequal treatment, whether on the basis of national or ethnic origin, religion, age, gender or other traits. Diversity presents valuable potential for Energie AG as an international company group. We respect the unique nature of each individual, and are committed to tolerant and respectful conduct as well as open communication. The effects of this include promoting a climate of appreciation and respect for all employees within the company. Behaviours aiming towards fair and trusting interaction with one another are supported.

Linz, Austria, 30 November 2018

The Board of Management of Energie AG Oberösterreich