Compliance

Observance of the legal requirements and rules and regulations is a matter of course for APG. As APG attaches great importance to compliance, the company has set the strictest compliance standards. 

Compliance at APG

APG complies with the current laws, regulatory provisions and external and internal rules. APG views compliance regulations as an integral part of its corporate philosophy. These regulations form the framework for APG’s internal guidelines. 

Prevention of corruption

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 European and Austrian provisions of capital market legislation is a matter of course for APG. APG has drawn up a set of principles for handling inside information as well as organisational measures for preventing misuse and dissemination of inside information. 

Codes and business practices

Code of Conduct

APG, Austria’s leading transmission system operator, has been certified as an independent transmission system operator (ITO) since 12 March 2012 by means of formal notification. APG coordinates and controls the cross-border flow of electricity in close collaboration with the grid operators in neighbouring European countries and, as a member of the European Network of Transmission System Operators for Electricity (ENTSO-E), ensures a long-term, sustainable power supply in Europe. 

APG is keenly aware of its responsibility towards the business world, the environment and society in general and acts in line with the following principles: 

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

Clear and open communication 
APG engages in open and objective dialogue with all stakeholders. It is important to APG to address its key positions on energy policy issues in a transparent manner. APG ensures that its actions are understandable and clear. 

Confidentiality 
As subsidiary of a publicly traded company APG is subject to European and Austrian laws and regulations pertaining to capital markets. Ensuring their in-house implementation falls under the responsibility of our compliance officer. 

Anti-corruption 
APG has a zero-tolerance policy towards unfair business practices and rejects any type of corruption and bribery. 

Responsible action 
APG supports human rights and respects the dignity of each individual. It firmly rejects any form of child labour or forced labour. APG expects its business partners to embrace these values. 

Compliance with the law and contractual fidelity 
APG complies with applicable law and honours its agreements and contracts. APG is committed to the Austrian Corporate Governance Code and to the EU’s unbundling regulations. 

Human resources 
Highly skilled and motivated employees are the basis of APG’s success. Its employees are characterised by their excellent qualifications, personal commitment and identification with our corporate goals and principles. APG offers all employees individual opportunities for development and bright future prospects. Its goal is to adjust working conditions to employees’ personal situations so that a healthy work-life balance is possible, enabling APG to achieve long-term collaboration with its employees. Loyalty to the company is important to APG. This includes constructive criticism which all APG employees express openly and in a proper form within the company. APG works with all people, regardless of their gender, age, religious beliefs, culture, skin colour, education, social origin, sexual orientation or nationality. APG firmly rejects any form of discrimination or psychological or sexual harassment. Good leadership is a crucial requirement for corporate success. Its pillars are subject-area expertise and social skills, open and direct communication, clear and unbureaucratic decision-making structures, constructive criticism and openness towards innovation. 

Customers 
Customer orientation is particularly important to APG. Providing excellent service and expertise, fair market conditions and reliability in performance are all part of APG’s mandate. 

Suppliers 
APG works collaboratively with its suppliers and requires that they comply with its quality standards and sustainability principles. 

Competition 
APG is committed to fair competition. It rejects 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 its fields of activity, APG is guided by the principle of sustainability – holistically taking into consideration profit, environmental protection and safeguarding the interests of employees and society as a whole. 

Code of conduct for lobbying activities in accordance with Section 7 of the Austrian Lobbying Act of 2012 (Lobbying- und Interessenvertretungs-Transparenzgesetz, LobbyG)

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 corporate management and is intended to provide a valuable contribution to solving energy and economic policy challenges as well as guaranteeing stable and fair general conditions. Within the context of its social responsibility, APG actively supports this process by providing expertise and also advocates for 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 its 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 its corporate mission statement and its fundamental values (Code of Conduct), APG is committed to responsible, sustainable behaviour. Its actions are in keeping with its public stance. In dialogue with its stakeholders from politics, administration, business and society, APG is guided by substantive stances and contributes its knowledge constructively to the decision-making process. 

Compliance with legal provisions 
APG’s 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 Guidelines on Good Governance. APG registers all corporate lobbyists in the Lobbying Register. 

Integrity and fairness 
Integrity is a fundamental component of APG’s corporate culture and also forms the basis for all of its lobbying activities. APG does not use dishonest or improper means in the acquisition and dissemination of information for the political decision-making process or in the assertion of interests. 

Prohibition of corruption or other reprehensible behaviour 
APG does not offer inadmissible advantages to officials, nor does it offer the prospect of such advantages. It avoids any semblance of improper or illegal behaviour. 

Respect 
APG treats all officials in an open and respectful manner. It gathers prior information on any restrictions and incompatibility rules which the official is subject to, provided such rules have been publicly communicated, and respects these. 

Honesty 
APG publicly discloses its corporate interests and business policies. Transparency is an integral part of its lobbying activities. Officials are therefore always provided with truthful, up-to-date and correct information on issues that affect APG’s corporate interests. APG does not present facts in a manner that may be misleading. 

Confidentiality/non-disclosure 
APG ensures that confidential information is handled with the required discretion. Such information is neither disseminated nor used for other purposes.  

Fair business practices

In its corporate mission statement, APG expresses its commitment to fair business practices. Corruption and bribery do not stand a chance at APG. A corporate guideline helps employees to rapidly identify unfair business practices and determine how to react correctly to these.

The key points of the guideline are as follows: 

• 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 light refreshments or a simple meal – 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 case of doubt. 

• When cooperating with civil servants and public officers, 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, light refreshments, simple meals). Invitations that could be construed 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 secondary employment to the company, and this employment must be authorised by the company. 

• APG, in turn, expects its business partners to adhere to its internal guidelines.