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Compliance

We are legally responsible for ensuring a secure supply of electricity in Austria.

We are monitored by E-Control, the state regulator, and funded via the network usage fees paid by electricity consumers. In awareness of this great responsibility, we subject ourselves to the highest of compliance standards.

Compliance at APG

APG complies with the current laws, regulatory provisions and internal rules. We view compliance regulations as an integral part of our corporate philosophy. These regulations form the framework for the internal rules of APG.

Anti-Corruption Guideline

A Compliance Officer coordinates implementation of APG’s Anti-Corruption Guideline and is therefore the first point of contact for making reports, asking questions and obtaining information about corruption or bribery. The compliance organisation is headed up by the Compliance Officer, who is supported by a compliance team. The system ensures adherence to compliance guidelines and, in particular, implementation of the principles and values of the Code of Conduct. The Compliance Officer provides regular reports on the activities of the compliance organisation to the Management Board as well as ad-hoc reports when needed. Our business partners are invited to turn to their contacts at APG for more information.

Financial market compliance

As a subsidiary of an exchange-listed company, observance of the Stock Exchange Act (BörseG) and other capital market rules and regulations is a matter of course for us. This also applies to implementation of the Issuer Compliance Regulation issued by the Austrian Financial Market Authority, with which APG is likewise required to comply.

Code of Conduct

Collaboration

Our collaboration with all of our stakeholders is cooperative, fair and reliable. We attach great importance to dealing with conflicts in a constructive manner.

Clear and open communication

We engage in open and objective dialogue with our stakeholders. It is important to us to review our key positions on questions of energy policy in a transparent manner. We ensure that our actions are understandable and clear.

Confidentiality

As the subsidiary of an exchange-listed company, we are subject to the Issuer Compliance Regulation of the financial markets. Compliance with this regulation is ensured by the Compliance Officer.

Anti-corruption

We have a zero-tolerance policy towards unfair business practices and any type of corruption and bribery.

Responsible action

We speak up for human rights and respect the dignity of each individual. We firmly reject any form of child labour or forced labour. And we expect that these values are also embraced by our business partners.

Compliance with the law and contractual fidelity

We comply with applicable law and honour our agreements and contracts. We are committed to the Austrian Corporate Governance Code and to the EU's unbundling regulations.

Human resources

Qualified and motivated employees are the basis of our success. Our employees are characterised by their excellent qualifications, personal commitment and identification with our corporate goals and principles.

We offer all employees individual opportunities for development and bright future prospects. It is our goal to adjust working conditions to our employees’ respective personal situations so that a healthy work-life balance is possible, enabling us to achieve long-term collaboration with our employees.

Loyalty to the company is important to us. This includes constructive criticism which we express openly and in a proper form within the company.

We work with all people, regardless of their gender, age, religious beliefs, culture, skin colour, education, social origin, sexual orientation or nationality. We firmly reject any form of discrimination, mobbing or sexual harassment.

Management competency is a crucial requirement for corporate success and its pillars are professional and social competence, open and direct communication, clear and unbureaucratic decision-making structures, constructive criticism and openness towards innovation.

Customers

Customer orientation is particularly important to us. Providing excellent service and competence, market-appropriate terms and reliable performance are all part of our mission.

Suppliers

We work collaboratively with our suppliers and require that they comply with our quality standards and sustainability principles.

Competition

We are committed to fair competition. We reject any form of collusion under anti-trust law, be it with regard to prices, market share, capacity, division of regional markets or price-fixing.

Sustainability

In all of our fields of activity, we are guided by the principle of sustainability – holistically taking into consideration economic success, environmental protection and safeguarding the interests of both our employees and the company itself.

Code of conduct for lobbying activities

(Code of conduct for lobbying activities in accordance with § 7 Austrian Lobbying Act 2012 [LobbyG 2012])

Lobbying is a key part of democratic processes. The dialogue with political and civilian decision-makers counts among the most important elements of our sustainable company management and should provide a valuable contribution to the solution of energy and politico-economic challenges, as well as guarantee stable and fair general conditions. Within the context of its social responsibility, APG actively supports this process through the introduction of know-how and also advocates a constructive and transparent discussion and decision-making process.

With this in mind and in accordance with the Austrian Lobbying Act [Lobbying- und Interessenvertretungs-Transparenzgesetz ("LobbyG")], APG has established a code of conduct for lobbying activities. This regulates our relations with stakeholders in Austria as well as at a European and international level and defines principles for transparent and responsible lobbying.

Professionalism

In line with our corporate mission statement and our fundamental values (code of conduct), we are committed to a responsible and sustainable performance. Our actions are in keeping with our public stance. In dialog with our stakeholders from politics, administration, business and society, we orientate ourselves on substantive positions and introduce our knowledge constructively into the decision-making process.

Compliance with legal provisions

Our actions are carried out in compliance with the national, European and international laws, in particular the provisions of the Austrian Lobbying Act, as well as the Good Governance Guidelines. We register all corporate lobbyists in the Lobbying Register.

Integrity and fairness

Integrity is a fundamental component of our corporate culture and also forms the basis for all our lobbying activities. Dishonest or improper means are not used in the acquisition and dissemination of information for the decision-making process or in the assertion of interests.

Prohibition of corruption or other reprehensible behaviour

We do not offer inadmissible advantages to officials, nor do we offer the prospect of such advantages. We avoid any semblance of improper or illegal behaviour.

Respect

We treat all officials in an open and respectful manner. We gather prior information on any restrictions and incompatibility rules which the official is subject to, provided such rules have been publicly communicated, and respect these.

Honesty

We openly declare our corporate interests and business policies. Transparency is an integral part of our lobbying activities. Officials are therefore always provided with truthful, up-to-date and correct information on issues that affect our corporate interests. We do not present facts in a manner that may be misleading.  

Confidentiality/non-disclosure

We ensure that confidential information is handled with the required discretion. Such information is neither processed nor used for other processes.

Fair Business Practices

In our corporate mission statement, we are committed to fair business practices. Corruption and bribery do not stand a chance at APG. 

A corporate guideline provides our employees with support in the rapid recognition of unfair business practices and in how to react correctly to these.

The key points of the guideline are:

  • As a basic principle, while carrying out their duties for APG, employees are as equally prohibited from offering or awarding benefits (gifts or discounts) as they are from demanding, allowing themselves to be promised, or accepting benefits for themselves or a third party.
  • However, small tokens of appreciation which are appropriate for the practice of polite interpersonal relations – such as the provision of refreshment drinks or a snack, for example – are permitted. At any rate, care must be taken in the selection of these tokens of appreciation in order to prevent the recipient being given any impression of impropriety or incorrect behaviour.
  • Business and personal life must be kept strictly separate. Expenditure which crosses over into both areas must be paid privately in the event of doubt.
  • When cooperating with civil servants and public officers, our executives and employees are asked to exercise particular sensitivity. In the course of meetings, civil servants and public officers may be entertained within the customary setting (for example, refreshment drinks and snacks). Invitations that might be interpreted as attempted bribery or inducement are prohibited without exception.
  • Fair awarding of contracts: potential or active suppliers may neither be given preferential treatment nor put at a disadvantage.
  • The payment of donations must be carried out with transparency and, as a basic principle, must not be made to individuals or private accounts.
  • Employees must declare any supplementary employment to the company, and this employment must be authorized by the company.
  • We, in turn, expect our business partners to adhere to our internal guideline.
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