Ethics and integrity
EVN places great importance on the integrity and legally compliant behaviour of its employees and business partners. The Code of Conduct with its ten subject areas forms the basis for all compliance measures in the Group. It covers corporate principles that extend beyond legal requirements and defines behavioural guidelines for EVN’s employees. Reference points are established for day-to-day business activities based on reliability, transparency, trust and quality in interactions with internal and external partners. These rules are aimed at encouraging responsible, self-reliant actions by employees. The EVN Code of Conduct is regularly adapted to reflect current developments, above all changes in legal requirements, and is available in German, English and the languages of the foreign subsidiaries. It is based on internal management directives and applicable national laws as well as international regulations that include the OECD guidelines and agreements, the UN Global Compact and policy statements and principles issued by the International Labour Organization (ILO).
- Also see www.evn.at/Code-of-conduct.aspx.
- GRI indicator: Values, principles, and norms of behaviour (G4-56)
The Corporate Compliance Management Department (CCM), a staff department reporting directly to the Executive Board, was created in 2012/13 to develop, operate and improve the Compliance Management System (CMS). The CMS defines a standardised framework for the entire Group, which is designed to support employees in honest and legally compliant behaviour in everyday business activities.
The CCM staff was expanded in 2015/16 to include a data protection expert in preparation for implementation of the EU Data Protection Directive in 2018. The installation of a data protection management system (DMS) will enable
- the creation of organisational and process structures for data protection,
- the preparation, further development and monitoring of internal data protection guidelines, and
- the coordination, training and support for employees involved with the DMS.
- Also see Internal audit and risk management
- GRI indicator: Internal and external mechanisms for compliance and integrity (G4-57)
EVN has carried out a programme for the extensive training of employees on ethical and legally correct behaviour since 2013/14. A compliance box was developed for this purpose. EVN’s Code of Conduct forms the basis for these training sessions, which last at least 2.5 hours. Compliance training courses were held for over 550 employees and managers in four different languages and five countries during the reporting year.
- GRI indicators: Total hours of employee training on human rights policies or procedures (G4-HR2); Anti-corruption measures trainings (G4-SO4)
Continuing development of compliance management
The EVN experts review new compliance-relevant content and issues on a regular basis. This information is integrated in the compliance box, where necessary, based on a risk assessment. Additional support is provided for issues with a high risk exposure in special training courses. In addition to information on the EVN Intranet, e-learning modules are also available to all employees as a means of strengthening their awareness for compliance and reinforcing the course content. Special courses are also offered for managing directors, managers of infrastructure projects and salespersons.
Prevention of non-compliance
Non-compliance is designated as a risk factor in EVN’s internal risk management system, and appropriate instructions have been issued for all Group companies based on the EVN Code of Conduct. In addition, the internal audit department also reviews compliance-related requirements and rules during its project audits. Group employees have had access to a whistle-blowing platform in the EVN Intranet since 2014/15, which permits the confidential and anonymous reporting of concerns related to unethical or illegal actions. The reporting procedures are available to employees in the EVN Intranet and to business partners via designated e-mail addresses (e.g. email@example.com). A Group directive defines the procedures for dealing with the reported concerns and protecting the whistle-blower against reprisals.
Non-compliance represents a breach of the employees’ responsibilities and may lead to consequences under criminal law. Confirmed suspicions would result in prosecution under labour and/or civil law, depending on the severity of the case and the scope of the damage. Therefore, employees who unintentionally come into conflicts of interest or loyalty during the course of their work are advised to contact EVN’s compliance officer directly and without delay. Two suspected violations of the Code of Conduct (relating to procurement and a customer complaint) were reported through the whistle-blowing system during the reporting year. An internal investigation did not confirm these suspicions.
- GRI indicators: Reporting concerns related to integrity (G4-58); Examination of corruption risks (G4-SO3); Anti-corruption measures (G4-SO5)
EVN is committed to the unlimited protection of human rights in all areas of its activities. Compliance with human rights principles is the responsibility of the Executive Board, which is supported by the EVN compliance officer. An important tool for this protection is the inclusion of human rights clauses in contracts. These clauses cover investment and procurement practices, equal opportunity, freedom of assembly, right of collective negotiations, the abolishment of child labour and forced labour, complaint procedures, safety measures and the rights of indigenous people.
Review of compliance
The principles specified in the EVN Code of Conduct are binding for all employees and available to the general public. Since EVN requires the same strict compliance with its principles and values from suppliers and service providers, these firms are required to comply with EVN’s integrity clause. Sampling procedures are used to audit the human rights performance of suppliers in their business relations with the EVN Group.
- For EVN’s integrity clause for suppliers, see High sustainability demands on suppliers
- GRI indicators: Investment agreements with human rights clauses (G4-HR1); Number of reviews concerning the compliance with human rights and/or impact assessments (G4-HR9)
Special emphasis is placed on the protection of human rights with regard to the employment of security personnel, especially at EVN’s business locations in South Eastern Europe. Consequently, security personnel – either employed staff or external firms – are trained in the human rights aspects of the EVN Code of Conduct and the integrity clause. Human rights violations by security personnel can therefore be ruled out almost completely and are strictly sanctioned.
- GRI indicator: Training for security personnel on the issue of human rights (G4-HR7)
Rights of EVN’s employees and suppliers
For EVN and its subsidiaries at all locations, the right of free assembly and collective negotiation represents a cornerstone for the implementation of the Universal Declaration of Human Rights as well as the core work norms of the International Labour Organization (ILO). This right also forms an integral part of EVN’s integrity clause. EVN and its subsidiaries do not conduct any business activities that could endanger the free exercise of employee rights, in particular the freedom of assembly and collective negotiation. These rights are guaranteed by law in Austria and the other EU countries. In addition to the works council in the Austrian Group companies, EVN also supported the founding of an EU works council to monitor compliance with these and other human and employee rights at the Group’s facilities in the EU.
An analysis of the countries or geographical regions in which EVN’s international subsidiaries operate concluded that Russia is the only business location outside the EU to be classified by the authoritative institutions as a risk country for human rights. EVN therefore conducted extensive research into human rights compliance in these risk countries and intensified its own further education in this field. In the course of the internal training sessions on the EVN Code of Conduct, the department also ensures that the management of the Russian subsidiaries and facilities were made aware of the need to pay particular attention to compliance with human and employee rights. Assessments and feedback indicated that these rights are not endangered by the business activities of EVN or its subsidiaries in Russia. As a further precautionary measure to protect human and employee rights, EVN evaluates the relevant risks prior to the start of each international project.
- GRI indicator: Right to association and collective bargaining (G4-HR4)
As one of the key elements of international treaties, national social legislation, social guidelines and the ILO core work norms, equal treatment is a central factor for EVN’s positioning as a responsible employer. Any discrimination would be condemned and sanctioned under EVN’s compliance guidelines and personnel statutes. No incidents of discrimination on the grounds of ethnic, national or social origin, skin colour, gender, sexual orientation, religion or political orientation were reported during 2015/16.
- For more information on the application of EVN’s integrity clause for suppliers and service providers, see High sustainability demands on suppliers
- GRI indicator: Number of incidents of discrimination and actions taken (G4-HR3)