In the wake of its own digital transformation, the A1 Telekom
Austria Group continues to practice honesty, fairness, and transparency.The compliance management system provides a clear framework forresponsible conduct in the interest of safeguarding the Group’seconomic success and reputation in the long term.
The A1 Telekom Austria Group not only has its sights set on achieving its businessobjectives but is also on the way that this is done. The overriding principle here isand will remain honest and responsible conduct toward its customers,employees, shareholders, creditors, suppliers, other partners, and the public.
For a fair, sustainably successful businessdevelopement: the compliance managementsystem
On behalf of all its stakeholders, the A1 Telekom Austria Group is committed tokeeping its standards of integrity as a key component of its corporate culture.Only honesty, fairness, and transparency will safeguard the Group’s economicsuccess and reputation in the long term.
For this purpose, the A1 Telekom Austria Group has a sophisticated compliancemanagement system, the appropriateness and efficacy of which are regularlyreviewed. In order to avoid potential misconduct, the Group has defined clearrules for acting with integrity and in an ethically sound manner in all business re-lationships and has integrated appropriate controls into the business processes.
In order to respond appropriately to any misconduct, tips are collected via a dedi-cated whistleblower portal and dealt with in a strictly confidential mannor via astructured process. This makes it possible to remedy weaknesses and to continu-ously improve the compliance management system.
A scoping process identified the following as significant compliance topics:corruption prevention and integrity, antitrust law, data protection, and capitalmarket compliance. Group Compliance, with support from local compliance man-agers at the subsidiaries, ensures that the corresponding measures and tools areimplemented consistently in all business units. The A1 Telekom Austria Group’scompliance management system complies with internationally recognized stan-dards such as IDW PS 980, ISO 19600, and ISO 37001.
Code of Conduct: guidelines for actingresponsibly and with integrity
The Code of Conduct is a key tool of the A1 Telekom Austria Group’s compliancemanagement system. It is aimed at all employees and managers and helps topromote ethically and legally irreproachable conduct in the many decisions that
have to be made every day. For this purpose, it contains advice and rules for deal-ing fairly with stakeholders, gifts and personal benefits, confidentiality, conflictsof interest, protecting company assets, reporting violations, and communicating
the content of the Code of Conduct, and the Group’s whistleblower principles.The Code of Conduct was last revised in 2017, when it was expanded to includethe group-wide Guiding Principles of “Team, Trust, and Agility” (see “Employees”).
Group-wide guidelines also provide detailed assistance regarding specific topicssuch as anti-corruption and conflicts of interest, capital market compliance, andanti-trust law. For the “Anti-Corruption and Conflicts of Interest” guideline, theISO standards for compliance management systems (ISO 19600) and anti-cor-ruption management systems (ISO 37001) were taken into account.
Trainings on compliance topics is optimized for the target group and providedregularly in order to firmly embed the notion of integrity throughout the Group. Ingroup-wide training, the topics of anti-corruption, integrity, data protection, in-formation security, antitrust law, and capital market compliance are elucidatedwith a focus on actual practice. Employees and managers were trained in 7,600classroom trainings in 2018. In addition, employees and managers completedover 24,000 compliance e-learning courses in 2018. To resolve any unansweredquestions, employees of the A1 Telekom Austria Group can contact the “ask.me”compliance helpdesk, which dealt with a total of around 460 questions in 2018.
Embedding compliance in the corporateculture
Compliance is a central element of the corporate culture because it providesclear rules and guidelines for behavior in everyday business. Decisive factorshere include the example set by top management and all managers and the re-sponsibility of all employees for their own actions. With the aim of permanentlypreventing and uncovering potential risks within the A1 Telekom Austria Group,employees and external individuals can use the “tell.me” whistleblower platformto anonymously report information about potential misconduct. In 2018, thiscompliance tool received around 20 compliance-relevant tips, which were fol-lowed up with the utmost care and confidentiality.
If necessary, the A1 Telekom Austria Group responds immediately with appropri-ate measures and sanctions. If actual misconduct is found, the potential conse-quences range from education measures, process improvements, and repri-mands to dismissals or the termination of business relationships.
Successful audit of the compliancemanagement systems
In 2018, the A1 Telekom Austria Group’s compliance man-agement system wasrevised and its design was reviewed by a leading audit company. The A1 TelekomAustria Group was assured that the principles and measures presented are
“suitable for both identifying in due course and with reasonable assurance risksof material non-compliance with valid regulations concerning anti-corruption,capital market compliance, and anti-trust and for preventing such non-compli-ance.” In addition, it was attested that the compliance management system com-plies with the international ISO 19600 and ISO 37001 standards and meets therequirements of the US Foreign Corrupt Practices Act, the European Cartel
Law, and the UN Global Compact. ▬
Digital audit approaches using advanced analyticsmethods enable a thorough and thus a more infor-
mative audit of the effectiveness of the compli-ance management system. They allow potentialcompliance risks to be identified much more pre-cisely and investigated much more comprehen-sively. For example, structured SAP data analysesand process flow analyses are used for purposessuch as ascertaining compliance with require-ments and discovering irregularities in general.