Prevention of corruption
Wienerberger is committed to upholding the principle of free and fair competition, which includes a firm stance against any form of corruption. We have always pursued the target of zero corruption incidents. A Group-wide guideline on business gifts informs our employees on what is considered to be lawful behavior. It provides orientation regarding the circumstances under which giving or accepting gifts constitutes a criminal offence. The guideline defines the term ‘business gift’ and explains the difference between a business gift and other forms of expression of appreciation. Moreover, it distinguishes between gift-giving in the public and the private domains and specifies the corresponding rules of conduct. Finally, the guideline requires reports to be submitted to the Managing Board and/or the local management if a business gift has been either given or received. Anti-corruption training for employees of the local companies has to be provided by the local management and is subject to regular review by the holding company. The Wienerberger guideline on business gifts, which has been in force since 2010, is to be revised in the course of this year. The revision has become necessary on account of the transition to a division-based corporate structure and the associated shift of responsibilities to the business units.
Monitoring by the internal audit unit prevents corruption
Monitoring compliance with legal provisions and internal guidelines is one of the functions of the internal audit unit. In 2014, audits were performed in 20 companies, with a special focus on organization, purchasing, materials management, sales, human resources, corruption and anti-trust legislation. This corresponds to about one third of all operating companies of the Wienerberger Group. In the course of these audits it was found that all internal guidelines had been implemented in the countries audited and the employees concerned had been informed accordingly. Deviations from the guidelines, if any, were reported to the Managing Board and the Audit Committee, and the necessary measures, such as improvements in documentation, were agreed upon with the respective local management.
Four-eyes principle in business transactions
The application of the four-eyes principle in business transactions with third parties is another important instrument for the prevention of corruption. For each transaction establishing, modifying or terminating rights and obligations, two signatures of authorized signatories of the local unit are required. This requirement is laid down in international Group guidelines and helps to prevent corruption at international level.
Sanctions in the event of unlawful conduct
We expect all employees of the Wienerberger Group to act in conformity of the law. Any infringement constitutes a breach of official duty. Confirmation of a suspected infringement entails labor law or civil law consequences, depending on the extent of damage caused. In the period under review, no charges were brought against Wienerberger for suspected corruption, and no penalty payments were due.