Focus Area Compliance at HOCHTIEF

Compliance is a key element of our guiding principles. As an international provider of construction-related services, HOCHTIEF operates in countries with very different values, political and legal systems. The HOCHTIEF Vision and Codes of Conduct set out what is expected and required of employees with regard to compliance in all Group companies. They apply in all HOCHTIEF companies and are firmly established in our corporate culture today. Our Codes of Conduct incorporate both key statutory requirements and obligations under voluntary commitments that we have pledged to comply with and support. These include the UN Global Compact and the ILO Core Labour Standards.

HOCHTIEF expects all employees of HOCHTIEF companies to comply with the law as well as internal rules and to prove sincerity and fairness in all aspects of their business activities. Because an illegal or irregular conduct by employees is not only one of the ten biggest corporate risks for companies, but it can also have significant legal consequences for the respective employee. We expect the same from our contract partners and subcontractors.

HOCHTIEF's Compliance System is geared to prevention, using appropriate measures to guard against Compliance Violations. Everyone, executives as well as staff, is responsible for ensuring that Compliance Standards are met. Our Guiding Principle is clearly defined: no business deal is worth endangering the high degree of trust and the excellent reputation that HOCHTIEF enjoys. The Compliance organization team supports HOCHTIEF's employees in avoiding non-compliance and the resulting risks by providing targeted information, personal advice and regular training. Employees can report irregularities – anonymously or confidentially if they wish – via a whistleblower system.

We have been pursuing our systematic anti-corruption policy for many years already. HOCHTIEF became a member of Transparency International as early as 1999, for example.

Our objective:

We aim to set standards with our Code of Conduct.

You can find detailed information on compliance at HOCHTIEF and our directives here:

Compliance organization at HOCHTIEF

Top-level responsibility for Corporate Compliance is held by the CEO of HOCHTIEF Aktiengesellschaft. The Chief Compliance Officer reports annually to the Supervisory Board Audit Committee. Various units provide support for the work of the Chief Compliance Officer, including Corporate Compliance and Legal. All divisions have similarly structured compliance organizations. The compliance organization of each division is headed by a divisional compliance officer who reports directly to the Chief Compliance Officer. The divisional compliance officers’ responsibilities include implementing the HOCHTIEF compliance program, detecting compliance risks at an early stage, and taking suitable countermeasures. Each serves as a local liaison for divisional company employees, providing support in the implementation and onward evolution of the compliance system.

All HOCHTIEF divisions have a compliance committee that meets at least once a quarter under the chairmanship of the compliance officer. A compliance committee is made up of the divisional compliance officer, members representing the operating business, and members from individual functions such as human resources, auditing, and procurement. The compliance committees are tasked with advising and supporting the compliance organization in implementing the compliance program and integrating compliance into the business workflows and processes.

Our compliance system is geared to preventing compliance violations. Preventing corruption and antitrust infringements is the main focus of the compliance organization. Responsibility for compliance in other areas where violations can arise lies with the relevant organizational function, such as the corporate competence center for occupational safety, health, and environmental protection (OSHEP Center) or, in data protection matters, the HOCHTIEF Data Security Officer.