ÖBB Annual Report 2025

Group Management Report 180 Österreichische Bundesbahnen-Holding Aktiengesellscha ft Consolidate d Financial Statements | Group Managem ent Report 137 Since 2018, employees who are particularly committed to ÖBB’s corporate values have been honored with the ÖBB Employee Award in seven categories – including Colleague of the Year, Innovation of the Year, and Safety Role Model of the Year. ESRS G1-1.9 Regular training courses are held to strengthen the corporate culture. The e-learning module “The world of ÖBB – a compact overview of the Group” provides employees with an overview of the vision, mission, strategy, and values of the ÖBB Group. The corporate values are also part of management training and the annual preparation for employee appraisals. ESRS G1-1.10.g Compliance Compliance is responsible for the prevention, early detection and investigation of matters relating to white-collar crime and corruption. The ÖBB Group’s Compliance Office, which is responsible for investigating compliance-relevant reports, is part of ÖBB-Holding AG and is headed by the independent Chief Compliance Officer. In addition, organization and employment law ensures that there are independent compliance officers in the sub-group companies ÖBB- Personenverkehr AG, ÖBB-Infrastruktur AG, and Rail Cargo Austria AG. The Compliance Office is primarily responsible for the prevention, early detection and investigation of matters relating to white-collar crime and corruption. All governing bodies and employees of the ÖBB Group are considered public officials as set out in the Austrian Criminal Code. This means that stricter criminal law provisions on corruption apply and they fulfill the definition of “high-risk functions.” The ÖBB Group’s Code of Conduct 51 is the core of the company’s approach to compliance. This Code of Conduct is binding for all management bodies, managers and employees. It explains and supplements applicable laws, describes the ethical principles and general principles on which the ÖBB Group bases its business activities, and lays out the key elements of the corporate culture. It is available both on the intranet and publicly on the internet. ESRS G1-1.10.h; ESRS G1-3.20 Protection of whistleblowers Internal and external whistleblowers can report issues to the compliance organization at any time. A whistleblower system 52 has been set up within the ÖBB Group for this purpose. It makes it possible to receive and process reports of behavior that goes against the rules – in a structured and confidential form and while maintaining anonymity. In addition, reports can be made by telephone, post, e-mail and in person (in any case confidentially). Compliance is responsible for receiving, reviewing and, if necessary, distributing the information. The whistleblower system was implemented based on the requirements of the Whistleblower Protection Act and EU Directive 2019/1937. ESRS G1-1.10.a, c, e, 11 The Compliance Office is required by law to treat the identities of whistleblowers and any persons named in the whistleblowing alert in strict confidence, and to protect them. In accordance with the relevant statutory provisions, detrimental measures directed against the person providing the information are not permitted. ESRS G1-1.10.c Procedures for the prevention, detection, investigation and follow-up of reports The comprehensive compliance management system of the ÖBB Group ensures that the business activities of the ÖBB Group comply with legal requirements. The Compliance Office is obliged to consistently follow up on compliance-relevant information in order to remedy any irregularities. The investigators act on behalf of and in coordination with the Chief Compliance Officer. Other managers have no influence on the investigators. The results of these investigations are recommendations for potential improvements and sanctions. The case is pursued and the facts documented objectively and in full respect of the presumption of innocence. The data from tip-offs and the resulting compliance investigations are considered sensitive data that are subject to special confidentiality protection. The software ensures audit-proof data handling in compliance with the legal data protection requirements and the defined data security standards. The Compliance Office endeavors to evaluate the compliance management system on an ongoing basis, taking into account new legal requirements. To this end, compliance employees take part in selected training events. The compliance organization submits a comprehensive report on all compliance activities and investigations within the ÖBB Group to the supervisory bodies once a year. Furthermore, the group of entitled persons is informed accordingly on an ongoing basis throughout the year. ESRS G1-3.18 51 https://konzern.oebb.at/de/dam/jcr :8ab3fa09-25b2-4670-87e4-0ecdc89e775e/Code_of_Conduct_D_2020_ohneVerweise_V05.pdf. 52 https://www.bkms-system.com/bkwebanon/report/clientInfo?cin=ry8sbj&c=-1&language=ger. | MR137 E.  Non-financial statement E.1. General information E.2. Environmental inform ation E.3. Social information E.4. Governance information E.5. ESRS index