Business Principles and Anti-Corruption

Anti-corruption and preventing anti-competitive behavior are a key aspect of the material topic Economic Impacts and Business Principles. OMV is a signatory to the UN Global Compact. Although we are headquartered in Austria – a country with high business ethics standards – we operate in several countries in the Middle East, North Africa, Asia-Pacific, and Central and Eastern Europe that are defined as high risk by the Transparency International Corruption Perception Index. We strive to avoid the risks of bribery and corruption that are specific to our sector. We also highly value our reputation. Therefore, our highest priority is ensuring uniform compliance with our business ethics standards wherever we operate. Compliance with ethical standards is a non-negotiable value that supersedes any business interest. Absolute commitment to this objective is embedded at all levels at OMV from top management to every employee. Our business partners are also expected to share the same understanding of and commitment to ethical standards. Every company activity, from planning business strategy to daily operations, is assessed for compliance with ethical standards, such as the Code of Conduct and Code of Business Ethics.

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 Conduct 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, 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.)

Company management is committed to establishing and maintaining an ethical standard of trust and integrity in our day-to-day business. Our senior management signs a Compliance Declaration to confirm that their conduct is in line with the Code of Business Ethics. New senior management also receives onboarding to introduce OMV integrity standards.

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.

In 2020, face-to-face business ethics trainings were conducted with 496 employees. We also monitor the compliance of all of our operations with laws and regulations concerning capital markets law and antitrust 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 339 employees in 2020. ² All compliance data excluding Borealis. Borealis data is contained in the Borealis Annual Report.

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 980 ³ 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. 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 semi-annual risk analysis, which is part of OMV’s Enterprise-Wide Risk Management (EWRM).