Annual Report 2025 – ÖBB-Infrastruktur AG

ÖBB-Infrastruktur Aktiengesellschaft Group Management Report | Consolidated Financial Statements 143 The Compliance Office undertakes to consistently follow up on compliance-related reports to remedy any irregularities. The investigators act on behalf of and in consultation with the Chief Compliance Officer. Other managers have no influence on the investigators. The results lead to recommendations for improvement and sanctions to be imposed. Cases are investigated and documented objectively and in accordance with the presumption of innocence. Data from reports and subsequent compliance investigations are classified as sensitive data and are subject to special confidentiality protection. The audit-proof software meets the legally prescribed criteria for data protection and the defined criteria for data security. The Compliance Office strives to evaluate the compliance management system on an ongoing basis, taking into account new legal requirements. To that end, compliance staff participate in selected events. The compliance organisation submits a comprehensive report on all compliance activities and investigations within the ÖBB-Infrastruktur Group to the supervisory bodies once a year. Furthermore, the authorised group of persons is addressed on an ongoing basis throughout the year. Awareness One of the core tasks of the compliance organisation is to raise awareness of compliance-related issues among employees on a long-term and sustainable basis. Target group- and risk-oriented training courses and awareness-raising measures are carried out. These take the form of face-to-face events, training via video conference and an e-learning programme that is redesigned and rolled out every three years. The training courses focus, in particular, on the following topics to explain compliance concepts: Corruption (including bribery, accepting bribes and the granting of undue advantages), conflicts of interest (particularly in connection with procurement), white-collar crime, secondary employment and the whistleblower system. Due to their official capacity, all ÖBB employees can be regarded as persons in risk-bearing functions. Over 90% (previous year: > 90%) of all ÖBB employees with their own ÖBB e-mail address are covered by the training programmes offered (personal training and/or e-learning), including those identified as members of an administrative, management or supervisory body. In accordance with the definition used by the ÖBB Group, this includes the Supervisory Board members of ÖBB companies, as well as members of the Management Board, managing directors and executives at all management levels (control levels A and B). G1-2 Management of relationships with suppliers Sustainable procurement As a public sector contractor, the ÖBB-Infrastruktur Group is subject to the Federal Procurement Act (Bundesvergabegesetz) (BVergG 2018). In accordance with the principles of procurement law, free, fair and equitable competition, equal treatment of all applicants and bidders, as well as transparency, economic efficiency and environmental justice must be ensured. In addition to environmental considerations, the procurement process also takes social standards into account. Since 2021, a Supplier Code of Conduct has been added to the General Terms and Conditions. It defines ethical principles governing cooperation with ÖBB and must be accepted in the internal ÖBB procurement system ProVia prior to the commencement of cooperation. ÖBB, and consequently the ÖBB-Infrastruktur Group, ensure that tenders are conducted without discrimination. Where possible, tenders will be designed in such a way that regional suppliers and small and medium- sized enterprises (SMEs) can also take part. The ÖBB-Infrastruktur Group uses approaches that comply with public procurement law to ensure that sustainability requirements are met throughout the supply chain. Market-relevant factors (market maturity, strength of competition and sustainability risk etc.) play a role in the selection of the approach. This means, for example, that higher requirements can be set in a more developed market without significantly restricting the pool of bidders. This is based on the ÖBB Toolbox, which contains legally vetted sustainability criteria. In addition, the TCO-CO₂ model takes into account not only total costs but also emissions costs over the entire life cycle. We require relevant suppliers to undergo an external ESG assessment, in order to analyse their strengths and weaknesses.