Anti-corruption and anti-bribery metrics

[G1-4.21b] [G1-4.22, 24a, 24b] [G1-4.25a, 25b, 25c] [MDR-M.77c] [Voluntary] [NaDiVeG]

 

 

2025

2024

ESRS metrics

 

 

 

In-person training

 

 

 

Functions at risk currently covered in the ongoing training cycle for the in-person business ethics/anti-corruption training program

%

63

39

Functions at risk currently covered in the ongoing training cycle for the in-person competition law training program

%

82

38

E-learning program

 

 

 

Functions at risk covered in the e-learning program on business ethics/anti-corruption

%

97

n.a.

Other

 

 

 

Convictions for violation of anti-corruption and anti-bribery laws

number

0

0

Fines for violation of anti-corruption and anti-bribery laws

EUR mn

0

0

Confirmed incidents of corruption or bribery

number

0

0

Confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents

number

0

0

Confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery

number

0

0

Voluntary metrics

 

 

 

Whistleblowing cases in the OMV Group brought to the attention of the Compliance department via OMV’s whistleblowing mechanisms1

number

69

60

Confirmed incidents of conflicts of interest

number

0

n.a.

Confirmed incidents of money laundering or insider trading

number

0

n.a.

Sites with an ethics certification

%

100

n.a.

Sites assessed or audited internally on specific ethics issues

%

100

n.a.

1

Due to confidentiality restraints, no information can be disclosed on types of misconduct and measures taken.

[MDR-M.77b] The measurement of all metrics below is not validated by an external body other than the assurance provider.

[G1-4.21b] [MDR-M.77a] The percentage of functions at risk covered by the in-person and e-learning training programs is calculated as: the number of employees (full-time and part-time) who have attended training programs divided by the total number of employees identified in the target group for training programs, multiplied by 100.

[G1-4. 24a] [MDR-M.77a] The number of convictions for violations of anti-corruption and anti-bribery laws is counted on a case-by-case basis for these specific violations. Fines (EUR mn) for violations of anti-corruption and anti-bribery laws are based on the total amount of fines received for these specific violations.

[G1-4.25a] [MDR-M.77a] The number of confirmed incidents of corruption or bribery refers to cases where an employee verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business with OMV.

[G1-4.25b] [MDR-M.77a] The number of confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents refers to cases where an employee verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business for OMV.

[G1-4.25c] [MDR-M.77a] The number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery refers to incidents whereby a business partner verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business with OMV or a third party.

[Voluntary] [MDR-M.77a] The number of whistleblowing cases in the OMV Group refers to the number of reports regarding alleged misconduct/breach of law or internal regulations brought to the attention of the Compliance department via OMV’s whistleblowing mechanisms.

[Voluntary] [MDR-M.77a] Confirmed incidents of conflicts of interest refer to incidents where an employee verifiably fails to disclose a conflict of interest, leading to a confirmed incident of corruption or bribery (i.e., where an employee verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business with OMV).

[Voluntary] [MDR-M.77a] Confirmed incidents of money laundering or insider trading refers to incidents where an employee is officially found or proven through legal proceedings or regulatory enforcement to have engaged in money laundering or insider trading in violation of applicable laws.

[Voluntary] [MDR-M.77a] Sites with an ethics certification refers to the sites operated by OMV that are covered by external certification in accordance with the Auditing Standard (PS) 980 of the Institute of Public Auditors in Germany (IDW), disclosed as a percentage.

[Voluntary] [MDR-M.77a] Sites assessed or audited internally on specific ethics issues refers to the sites operated by OMV that are covered by the annual standardized reporting process on ethical issues and the annual risk analysis, which is part of OMV’s Enterprise-Wide Risk Management (EWRM) system, and disclosed as a percentage.

Business ethics/anti-corruption training (in-person)

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2025

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

1,178

824

47

n.a.

Total receiving training in the reporting year

402

152

13

383

Delivery method and duration (hours)

 

 

 

 

Classroom training

1

1

1

1

Computer-based training

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required

Three-year training cycle

Three-year training cycle

Three-year training cycle

n.a.

Topics covered

 

 

 

 

Definition of corruption

x

x

x

x

Policies (Code of Business Ethics, Ethics & Integrity Policy, Whistleblowing Directive)

x

x

x

x

Procedures regarding prevention and detection of corruption and bribery

x

x

x

x

Protection of whistleblowers

x

x

x

x

Business ethics/anti-corruption training (in-person)

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2024

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

920

723

59

n.a.

Total receiving training in the reporting year

357

344

22

844

Delivery method and duration (hours)

 

 

 

 

Classroom training

1

1

1

1

Computer-based training

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required

Three-year training cycle

Three-year training cycle

Three-year training cycle

n.a.

Topics covered

 

 

 

 

Definition of corruption

x

x

x

x

Policies (Code of Business Ethics, Ethics & Integrity Policy, Whistleblowing Directive)

x

x

x

x

Procedures regarding prevention and detection of corruption and bribery

x

x

x

x

Protection of whistleblowers

x

x

x

x

Competition law training (in-person)

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2025

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

850

181

45

n.a.

Total receiving training in the reporting year

449

88

19

n.a.

Delivery method and duration (hours)

 

 

 

 

Classroom training

1.5

1.5

1.5

n.a.

Computer-based training

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required

Three-year
training cycle

Three-year
training cycle

Three-year
training cycle

n.a.

Topics covered

 

 

 

 

Horizontal relationships/cartels

x

x

x

n.a.

Vertical relationships

x

x

x

n.a.

Abuse of dominance

x

x

x

n.a.

Dawn-raid procedures

x

x

x

n.a.

Competition law training (in-person)

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2024

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

642

209

38

n.a.

Total receiving training in the reporting year

245

73

17

51

Delivery method and duration (hours)

 

 

 

 

Classroom training

1.5

1.5

1.5

1.5

Computer-based training

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required

Three-year
training cycle

Three-year
training cycle

Three-year
training cycle

n.a.

Topics covered

 

 

 

 

Horizontal relationships/cartels

x

x

x

x

Vertical relationships

x

x

x

x

Abuse of dominance

x

x

x

x

Dawn-raid procedures

x

x

x

x

Business ethics/anti-corruption (e-learning program)1

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2025

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

10,066

1,465

131

n.a.

Total receiving training in the reporting year

9,716

1,443

122

n.a.

Delivery method and duration (hours)

 

 

 

 

Classroom training

n.a.

n.a.

n.a.

n.a.

Computer-based training

0.75

0.75

0.75

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required: OMV

Two-year training cycle

Two-year training cycle

Two-year training cycle

n.a.

Topics covered

 

 

 

 

Definition of corruption

x

x

x

n.a.

Policies (Code of Business Ethics, Whistleblowing Directive)

x

x

x

n.a.

Procedures regarding prevention and detection of corruption and bribery

x

x

x

n.a.

Protection of whistleblowers

x

x

x

n.a.

1

This e-learning program is delivered every two years. As such no comparisonsare disclosed.

Competition law training (e-learning program)1

[G1-3.21a, 21b, 21c] [MDR-M.77c] [NaDiVeG]

 

2024

 

At-risk functions

Managers

Administrative,
management,
and supervisory
bodies

Other own workers

Training coverage (number)

 

 

 

 

Total target group

858

201

27

n.a.

Total receiving training in the reporting year

811

188

23

n.a.

Delivery method and duration (hours)

 

 

 

 

Classroom training

n.a.

n.a.

n.a.

n.a.

Computer-based training

0.75

0.75

0.75

n.a.

Voluntary computer-based training

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

How often training is required: OMV

Two-year training cycle

Two-year training cycle

Two-year training cycle

n.a.

Topics covered

 

 

 

 

Horizontal relationships/cartels

x

x

x

n.a.

Vertical relationships

x

x

x

n.a.

Abuse of dominance

x

x

x

n.a.

Dawn-raid procedures

x

x

x

n.a.

1

This e-learning program is delivered every two years. As such no comparisonsare disclosed.

[MDR-M.77b] The measurement of all metrics below is not validated by an external body other than the assurance provider. [G1-3.21b] [MDR-M.77a] Table on business ethics training (in-person training and/or e-learning):

  • Total receiving training in the reporting year refers to the total number of employees that completed the in-person and/or e-learning business ethics training.

  • Voluntary computer-based training: the term “voluntary” refers to training that is not mandatory in the reporting cycle.

[G1-3.21b] [MDR-M.77a] Table on competition law training (in-person training): Total receiving training in the reporting year refers to the total number of employees that completed the in-person competition law training program.

G1 Borealis business ethics and anti-corruption and anti-bribery

[G1-3.21b] [MDR-M.77c] [NaDiVeG]

At-risk functions

 

 

 

2025

2024

Training coverage

 

 

Total receiving training1

207

323

Delivery method and duration

 

 

Classroom training (hours)

n.a.

n.a.

Computer-based training (hours)

0.5

0.5

Voluntary computer-based training (hours)

n.a.

n.a.

Frequency

 

 

How often training is required

Annually

Annually

1

The 2024 figure was updated after a data review conducted during the 2025 reporting cycle, which resulted in revised definitions for training coverage.

[MDR-M77a] Borealis uses the following key performance indicators to assess its performance and effectiveness.

G1 Borealis metrics to evaluate its performance and effectiveness

[MDR-M77a]

 

Metric and definition

Unit

Methodology

2025

2024

Percentage of Borealis employees completing the e-learning on the Borealis Ethics & Integrity Policy, Code of Business Ethics, and Code of Conduct

%

The number of Borealis employees who complete the training as a percentage of the number of Borealis employees assigned to the training.

93

85

The number of ethics reports filed through the whistleblower hotline by Borealis’ own workforce

number

The data is sourced from EQS, the external service provider for the Borealis whistleblower hotline.
Unsubstantiated cases are counted, unless the reported grievance obviously does not constitute an instance of misconduct.

79

62

The number of instances of non-compliance or recommendations from recertification or surveillance audits based on ISO 37301/37001

number

The external auditor conducts the mandatory annual audit of Borealis GmbH. Thereafter, a report describing each instance of non-compliance is issued and shared.

2

2

[MDR-M77b] The measurement of all metrics below is not validated by an external body other than the assurance provider, unless otherwise stated. The number of instances of non-compliance or recommendations from recertification or surveillance audits based on ISO 37301/37001 is validated by the Austrian Standards certification body. The ISO certificates can be downloaded from the Borealis website: www.borealisgroup.com. For more details, see Borealis Group Annual Report 2025 – Group Management Report – Sustainability Statement.

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