48 of employees without a management function were trained on the issue of preventing corruption across the group. Measures taken and activities to prevent corruption are guided by the principles of the Austrian criminal code and the UK Bribery Act 2010. These include the obligation of the management staff of all units of the RZB Group to shape a corporate culture in which each and every form of fraud is unacceptable. Assessment and evaluation of the risk of fraud takes place periodically and is documented accordingly. Persons who provide services for us are subject to due diligence. The relevant procedures for avoidance of fraud are communicated clearly and put into practice effectively. Monitoring and review of these procedures takes place on a regular basis. The Group’s internal Anti-Corruption and Bribery (“ABC”) framework was revised in 2015 and is now even more strongly based on risk and prevention. Each member of staff is obliged to report serious violations of the CoC – such as market abuse, fraud, theft, embezzlement, bribery or corruption. This can be done in the form of an email to Compliance, a telephone conversation with a Compliance employee, in writing or via an external telephone hotline run by a service provider in the United Kingdom (group whistle blowing hotline). All allegations will be investigated. The group reacted immediately to previously reported occurrences of corruption. Appropriate disciplinary action is carried out in accordance with group regulations, up to and including dismissal. We analyze our rules on a regular basis in order to minimize the risks for the future as much as possible. Discussions on the topic of better identification of all sectors exposed to economic crime are usually carried out at Board level, or with the second level of management, and ensure appropriate awareness. The necessary measures and on-going efforts to provide in-depth training are implemented with the support of local Compliance departments or the Financial Crime Management departments. These also play a key role in avoiding corruption and anti-corruption controls, as well as in business activities in sensitive areas. Financial contributions or contributions in kind to political parties, politicians or related institutions are given only in accordance with strict rules and with the approval of the RZB AG Managing Board. Clear regulations in this regard are enshrined in the Code of Conduct and are monitored by Compliance. The RZB Group has maintained an internal control system for years. The reporting procedures in the form of directives for strategically important topics are a central element and the basis for an effective internal control system. These directives and instructions constitute our “company law”. They encompass the assignment of approval authority for group and company directives as well as department- and division-specific directives, process descriptions for the creation, quality inspection, approval, publication, implementation and monitoring of directives as well as regulations for their revision and repeal. The management of the respective group units is responsible for implementation of the directives. The “Confirmation of Compliance” process is initiated each year. Within the framework of this process, 58 group units must confirm that they have followed the relevant policies. If this cannot be entirely confirmed for individual units, these units must create a roadmap of how the gaps will be closed. Monitoring of the compliance with these group regulations takes place within the framework of audits by the group and local audit departments.
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