ÖBB Annual Report 2023

175 Group Management Report Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 130 This includes four focus areas: – Employees are to have the right to agree without coercion to the General Terms and Conditions of Employment and they may voluntarily terminate their employment at any time with reasonable notice. – Child labour, human trafficking and forced labour are in no way practiced, supported or tolerated in the activities of Rail Cargo Group. – The unwilling service of an employee, the exploitation of children as well as their use for dangerous work, corporal punishment or abuse is not tolerated. – Employees in their positions are, without exception, legally employed. Ensuring compliance with local laws for employment, study, internship or apprenticeship. A risk analysis for human rights violations was conducted in the Rail Cargo Group in 2020 to further develop this human rights policy and implement it in measures. Where priorities were identified, measures were also defined. One of the measures, awareness-raising and training on the topic of “human rights within the company”, was rolled out in 2021. In 2023, a review of the 2020 risk analysis took place. GRI 2-23 Safeguarding human rights in the supply chain In addition to the existing GTCs, a new Code of Conduct for Suppliers was implemented in 2021 as part of the Strategic Group Procurement project. As a result of this commitment, 100% of new contracts with suppliers have been concluded via the ÖBB procurement platform since 2022, in compliance with ethical principles and general principles. These include the prevention of corruption and anti-competitive behaviour, respect for human rights and the promotion of diversity and equal treatment, as well as the prohibition of forced labour. Evidence is also obtained from strategic suppliers as part of the independent CSR assessment and information on improving the management approach is shared. GRI 308-1 Other significant measures Compliance | Transparency | Data Protection | Human Rights (excerpt) DATA PROTECTION Risk assessment update on data protection TRANSPARENCY Environmental data externally audited | In 2023, work began on rolling out an internal control system for the Rail Cargo Group’s key environmental data. An external partner (TÜV SÜD) is commissioned to collect and verify the plausibility of the environmental data on site, at the location or in the company as part of the external audits in accordance with ISO 14001 using a risk-based approach. Confidential reporting and whistleblower system | Since April 2023, the confidential reporting system has enabled all Rail Cargo Group employees in Austria to confidentially report issues relating to topics such as “employee protection”, “environment”, “waste”, etc., as well as issues that cannot be mapped via standard processes, supplemented by the whistleblower system, which is available to all stakeholders. COMPLIANACE Optimisation of conduct and regulatory conformity & compliance as part of ÖBB’s corporate culture Regulations and Procedures | Detailed explanations of the Code of Conduct and related external legislation. Face-to-face trainings | Conducting comprehensive face-to-face trainings and video conferences for employees (incl. apprentices) in the ÖBB Group. E-learning Compliance | The partially complex matter of preventing white-collar crime and corruption is explained in a practical manner using examples from everyday professional life. E-learning is made available to employees and is also established in the onboarding process. In 2023, it was launched in Hungarian. MR130 |