|Code of Conduct|
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.