One focus of corporate governance activities during the year again related to the onward development of our compliance program. Compliance with the law and internal guidelines is an essential management responsibility at HOCHTIEF. A Code of Conduct first adopted in 2002 has been supplemented in the meantime by a comprehensive set of rules, the compliance program. This is regularly reviewed and updated as necessary. All members of the workforce are called upon to take an active part in its implementation. The statutory requirements are explained in greater depth and in concrete terms in various Group directives and circulars.

Fighting corruption was an important issue in the year under review. The Executive Board once again made unequivocally clear that it will not accept any corruption- related infringement. Breaches of the rules are not tolerated in any way and trigger appropriate sanctions against the members of staff concerned.

Compliance officers keep the HOCHTIEF workforce up to date on the main points of the law, the Code of Conduct and HOCHTIEF’s internal directives. Training is provided both in the classroom and using interactive e-learning programs—on combating corruption, for example. The focus in this training is on high-risk conduct such as corruption and collusive bidding. Compliance officers are also there to advise preventively on specific questions.