ÖBB Annual Report 2023

Group Management Report 174 Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 129 The Compliance area systematically follows up every compliance-relevant tip-off. Whistleblowers report facts with a suspicion of white-collar crime or corruption to the compliance organisation at any time. This process of communication takes place by telephone, by post, by e-mail and also in person, but in any case confidentially. Anonymous reporting is also a possibility. In addition, an electronic whistleblower system was introduced. GRI 2-24, 2-25, 2-26 In addition, audits and risk analyses are performed independently of events. Furthermore, Compliance supports the legal departments of the ÖBB-Group in the area of competition law. The ÖBB-Group endeavors to evaluate the compliance management system on an ongoing basis and to further develop it in consideration of new legal requirements. Compliance attends selected events in order to gain early knowledge of compliance-relevant developments. The involvement of Compliance in the integrity officer network of the Federal Office for the Prevention and Combating of Corruption was continued. Highlight Compliance 2023 As one of the core tasks of Compliance is to raise awareness of the contents of the Code of Conduct among ÖBB Group employees in the long term and sustainably, the newly designed e-learning programme was rolled out in Hungarian in 2023. Outlook Compliance 2024 In 2024, the redesigned e-learning programme is to be rolled out in English in the foreign companies. This serves to further raise the awareness of ÖBB Group employees for compliance risks that may arise in specific situations in their day-to-day work. Human rights The ÖBB-Group acts in accordance with legal requirements in Austria, in Europe and at all company locations outside Europe. The fundamental rights granted under the Constitution, in particular the principle of equality under the Federal Constitutional Law, as well as the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR) apply. Independent courts monitor compliance with these rights. The ÖBB Group, as a member of the Chamber of Commerce, is also committed to its principles of “human rights, environmental standards, social standards” and is aware of its own social responsibility. In addition, there are further tangible requirements and measures in the area of human resources with regard to equal opportunities, diversity and inclusion (see Chapter G.11). Continuous development is also essential for the ÖBB Group in the far-reaching area of human rights. In 2023, levers for potential improvements were identified on the basis of an analysis of the market environment and a screening of international frameworks. This was based, for example, on the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights and the International Labour Organisation (ILO) Convention. The potential identified is then discussed with the subject matter experts and then implemented step by step in existing policies. ÖBB-Operative Services GmbH & Co KG, a subsidiary of ÖBB-Infrastruktur AG, is an internal service provider primarily responsible for cleanliness and safety at railway stations. It is particularly important in your working environment to treat all people with whom you interact as a company – both employees and customers – with dignity and respect. It is based on respect of human rights. All employees at ÖBB-Operative Services GmbH & Co KG are trained to withdraw from dangerous situations and to regard de-escalation as the most important premise for action. The internal work instructions and the internally developed standards of conduct also reflect this approach. The Rail Cargo Group employs approx. 5,900 people in 15 countries. The Management Boards of Rail Cargo Group and the respective Managing Directors signed the “Children’s Rights, Human Rights and Forced Labour Policy” in 2019. Accordingly, the human rights policy introduced in 2019 is intended to ensure the human rights of all employees at all sites and to rule out labour practices that violate human rights. | MR129