Business principles and anti-corruption management

Business ethics regulatory framework

The OMV Group follows a zero-tolerance policy with regard to bribery, fraud, theft, and other forms of corruption. Based on this policy, the OMV Group is committed to detecting any potential policy violations at the earliest stage, thoroughly investigating any such incidents of non-compliance and determining appropriate organizational measures or sanctions for the individuals involved. The integrity of our employees is the foundation for the trust placed in our Company by our customers, suppliers, and other stakeholders.

The regulatory instruments at OMV that establish ethics principles and standards and guide our approach to ethical conduct are our Code of Business Ethics, an internal policy applicable to OMV employees, and our Code of Conduct1Our Code of Conduct and a brochure with the key elements of our Code of Business Ethics are available at: www.omv.com/en/business-ethics-and-anti-corruption, an external policy governing the work with our business partners and stakeholders. The procedures established by these documents are implemented at every fully consolidated subsidiary of OMV and apply to everyone who works for OMV or in the name of OMV. We require compliance with international business principles from all parties with whom we enter into partnership agreements, such as joint ventures. Companies performing services for OMV (i.e., suppliers) must follow anti-bribery procedures that are consistent with the principles of OMV’s Code of Business Ethics and with OMV’s business ethics standards, as defined in the Code of Conduct. (For more details, see Supply Chain: Supplier sustainability compliance.)

OMV strives to earn stakeholders’ confidence by implementing a high standard of corporate governance, transparency, and predictability. OMV has therefore committed itself to compliance with the Austrian Code of Corporate Governance, and, in this context, through its Code of Business Ethics forbids any support of political parties, including donations. We follow political and regulatory initiatives (both at EU and national levels) in our areas of interest, including energy, environment, climate change, trade, and others. OMV has a dedicated department for Public Affairs activities. We are fully in line with all reporting obligations at the national and EU levels, and we are fully compliant with all transparency requirements.

OMV supports the Paris Agreement. This position is embraced by OMV at all organizational levels, including our activities in various interest groups. In addition, OMV has started to regularly verify whether the main interest groups of which the company is a member support the Paris Agreement.

OMV Compliance Management System

OMV has set up a comprehensive Compliance Management System including policies, audits, and trainings. The system aims to anchor OMV’s business ethics policies throughout the organization and to ensure their correct implementation. OMV introduced a Group-wide online training program for business ethics. 11,144 employees completed the online training. In addition, face-to-face business ethics trainings were conducted with 514 employees. We also monitor the compliance of all of our operations with laws and regulations concerning capital markets law and competition law as well as international trade sanctions and embargoes that are applicable to OMV. Face-to-face trainings in these other compliance areas were conducted with 482 employees in 2019.

OMV employees are encouraged to regularly participate in compliance training covering topics that are relevant to various types of jobs. The Compliance Management System is implemented Group-wide through collaboration between centrally based management units and local compliance officers in all countries in which OMV operates. This international compliance organization, which is dedicated to ensuring Group-wide implementation of OMV’s ethical standards, comprises 37 compliance experts.

In 2013, OMV became the first organization in Austria to comply with the comprehensive IDW Assurance Standard 980. The IDW Assurance Standard 980 is the benchmark certification standard for DAX and ATX companies.

The OMV Compliance Management System is regularly reevaluated and was recertified under IDW PS 9802IDW PS 980 regulates the Principles for the Proper Performance of Reasonable Assurance Engagements Relating to Compliance Management Systems. The corresponding English version is IDW AsS 980. in 2017. Both external and internal risk factors, in particular changes in the regulatory framework, as well as recent developments or incidents are monitored on an ongoing basis to evaluate their possible impact on OMV’s current risk exposure. This ongoing risk analysis also includes an institutionalized semiannual risk analysis, which is part of OMV’s Enterprise-Wide Risk Management (EWRM).

1 Our Code of Conduct and a brochure with the key elements of our Code of Business Ethics are available at: www.omv.com/en/business-ethics-and-anti-corruption

2 IDW PS 980 regulates the Principles for the Proper Performance of Reasonable Assurance Engagements Relating to Compliance Management Systems. The corresponding English version is IDW AsS 980.