Page 69 - KELAG Annual Report 2019
P. 69

speakers from a law firm since May 2010. Invitations to the
           The compliance management system (CMS) of KELAG and   training  sessions  are  extended  to  the  respective  level  of
           its  subsidiaries  has  been  implemented  since  2010.  This   management that is responsible for sending employees in
           system ensures that the probability of legal infringements   their areas on training. In the reporting year, the training
           by employees of the Group is kept as low as possible. It thus   format was changed to e-learning to give employees more
           serves  to  protect  both  the  company  as  well  as  every   flexibility. In total, 89 employees participated in compliance
           individual  employee,  while  making  a  contribution  to   training – 11 persons thereof participated in e-learning on
           safeguarding the business value in the long term. The CMS   the topic of anti-trust law and 20 persons on the topic of
           of  KELAG  and  its  subsidiaries  (KI-KELAG  International   preventing corruption, managers being around 50 % of this
           GmbH,  KNG-Kärnten  Netz  GmbH  and  KELAG  Energie  &   key personnel. Top management received personal training
           Wärme GmbH) is designed to promote a greater awareness   on a separate occasion.
           among  employees  and  managers  of  legal  risks  and  has   GRI 205-2
           been certified since 2014 in accordance with ONR 192050
           in  the  risk  areas  of  anti-corruption  law,  data  protection
           legislation,  anti-trust  law,  unfair  competition,  Austrian   The code of conduct applies uniformly for KELAG. Foreign
           Federal  Act  Against  Unfair  Competition  (UWG)  and   subsidiaries can take into account national particularities in
           procurement law. In the course of the annual surveillance   implementing  the  code  of  conduct  if  and  insofar  as  the
           audit  performed  by  the  independent  certification  body   basic principles of the group-wide code of conduct are not
           Austrian  Standards,  certification  in  accordance  with  the   compromised. Through its action, KELAG aims to promote
           international standard ISO 19600 was also obtained for the   the  further  diffusion  of  the  principles  established  in  the
           first time at the end of 2016. The standard is intended to   code of conduct. The companies with which KELAG has a
           help  managers  and  employees  maintain  compliant   business relationship are therefore encouraged to abide by
           behaviour. Further objectives include the evaluation of the   the  guidelines  of  the  KELAG  code  of  conduct.  If,  in  the
           effectiveness   of   compliance   measures   and   the   course of such business relationships, the code of conduct
           communication  of  these  as  well  as  ongoing  process   conflicts  with  another  company’s  ethics  policies,  the
           improvement.                                  company  will  do  its  best  to  find  a  mutually  acceptable
             GRI 103-1, 103-3, 102-17                    solution.  The  code  of  conduct  is  the  basis  for  further
                                                         company  guidelines  which  can  take  into  account  both
                                                         industry-specific and country-specific particularities.
                                                           GRI 102-16, 102-17
           As part of the implementation of the CMS, the possibility of
           addressing compliance  officers directly  and,  if  necessary,
           anonymously  in case  of  legal infringements  by  decision-
                                                         The  efficiency  of  the  KELAG  compliance  management
           makers  was  introduced  throughout  the  Group.  Any
                                                         system was proven again in the financial year 2019, there
           information obtained by the compliance officers in this way
                                                         being  no  cases  of  corruption,  legal  actions  for  anti-
           must be treated with the requisite care and confidentiality.
                                                         competitive   behaviour,   non-compliance   with
           Preventive measures are, however, the focus of the CMS. In
                                                         environmental  laws  or  violations  in  connection  with
           light  of  this,  compliance  work  focuses  on  training  and
                                                         marketing  and  communications  or  socio-economic
           presentations  as  well  as  individual  consultation  and
           information  on  specific  issues,  where  necessary.  Group
           compliance  training  has  been  conducted  annually  by   GRI 205-3, 206-1, 307-1, 417-3, 419-1
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