In order to be perceived as a trustworthy partner by shareholders, customers, business partners, employees and society, compliance with all relevant laws, voluntary commitments and internal regulations as well as fair competition are of the utmost importance.

Compliance

Compliance principles form the basis of fair business behaviour and lay the foundation for social dialogue, especially with suppliers and business partners. Breaches of laws and illicit and non-compliant behaviour can entail far-reaching social and commercial effects. Stringent compliance with the company’s own and legal requirements is essential to ensure the trust of the stakeholders in the long term. Violations can lead not only to fines and loss of sales revenues, but also potentially to a loss of reputation. Data security issues are becoming increasingly important as information technology advances. Threats such as hacker attacks, data loss or the disclosure of confidential information pose significant risks to information security.

 

 

Value
Management

AMAG is committed to the principles of the Austrian Corporate Governance Code, and consequently to responsible corporate governance and control systems oriented to delivering sustainable value creation.

AMAG has a comprehensive compliance system encompassing guidelines, audits and training. Related regulations are contained in AMAG’s guidelines on anti-corruption, data protection, commercial sales representatives, anti-trust and issuer compliance. The guidelines are reviewed annually in accordance with the internal control system (ICS), updated as necessary and distributed in a regulated process. In addition, training courses are offered in both face-to-face and virtual form. The AMAG code of conduct supplements the guidelines and forms an essential component of the compliance program. It covers topics such as fair and free competition, avoidance of conflicts of interest, protection of information and data, corporate policy, human rights and the reporting of misconduct. The code of conduct can be found on the company website together with the compliance regulations for suppliers. The compliance rules are communicated actively to all suppliers and integrated with the general terms and conditions of purchasing. AMAG’s suppliers are expected to comply with these principles.

For more informations, please see annual report 2021

Targets

Target 2021: 

  • Continuous further development of the compliance system: No violations

Central measures:

  • Further development of the compliance system
  • Reviews of legislative amendments: Evaluation of the whistleblower system according to expected legislation
  • Ongoing evaluation of existing e-learning training courses
  • Training courses for individuals working in confidentiality areas and participation in relevant events (compliance seminars, further training)
  • Compulsory e-learning courses for all employees affected and in-depth training for data protection coordinators

2022 target / medium term:

  • Continuous further development of the compliance sys-tem: No violations
Results

Results: 

 

In the 2021 reporting period, no reports were submitted via the compliance hotline or to the relevant departments. Furthermore, no proceedings due to anti-competitive behaviour or violations of antitrust and monopoly law were reported or ascertained at AMAG. Moreover, no fines were paid due to non-compliance with laws and regulations in the social and business area in 2021.  

The AMAG code of conduct supplements following international standards are endorsed:

  • The ILO Declaration on Fundamental Principles and Rights at Work, in particular non-participation in child labour, forced labour or debt bondage
  • The UN Guiding Principles on Business and Human Rights
  • The Aluminium Stewardship Initiative (ASI). As a founding member, AMAG actively contributes to sustainability and transparency along the guidelines. aluminium value chain and promotes the implementation of responsible practices. The upholding of human rights is one of the requirements of the ASI and this is examined and monitored in the course of ASI certification.

The standards and values anchored in the aforementioned international standards are equally reflected in AMAG’s guidelines and procedural instructions, and form the binding framework for action for employees, business partners and suppliers:

  • Code of conduct: This governs dealings describes how AMAG and all its subsidiaries should deal with the special responsibility they bear towards society as well as towards their business partners, shareholders shareholders and employees, and it supports employees and forms the basis of daily activities. The code of conduct can be found on the company website together with the compliance rules for suppliers.
  • Compliance rules for suppliers: The basic sustainability requirements of supply chains with respect to management, human rights, occupational health and safety, environmental protection and energy efficiency, among other areas, are defined in the compliance rules for AMAG suppliers. The principles defined with regard to human rights include the right to form or join independent union representation, fair treatment of employees with respect to suitable working times, regular holidays and performance-related remuneration. They are communicated actively to all suppliers available on the AMAG website and are integrated into our AMAG’s general purchasing terms and conditions. AMAG’s suppliers are expected to comply with these principles. conditions of purchase.

Human rights and responsibility in the supply chain

As a core element of responsible corporate governance, AMAG respects and promotes compliance with human rights, both within its own company and in the supply chain. Employees are treated according to the principle of equal opportunities without distinction on the basis of race, colour of skin, gender, religion, membership of a group, origin or other status. Suppliers and business partners are expected to comply with the same high standards as AMAG in relation to human rights. AMAG thereby acknowledges its responsibility to respect internationally applicable human rights, and also takes into account non-financial criteria such as environmental and safety standards and respect for human rights when selecting suppliers and business partners. 

 

 

Value
Management

Overall responsibility for compliance with human rights lies with the Management Board. Human rights aspects are implemented by the respective departments and monitored during the year, including as part of the purchasing process, and they are reported internally in the context of the sustainability committee. For example, the human resources department deals with human rights issues relating to labour law, while the purchasing departments are responsible for managing human rights aspects within the supply chain. Managers have a special role model function in this respect. They exemplify the values and bring them to bear in day-to-day management. Internal regulations and company agreements (code of conduct, works agreement on working time regulations, wage and salary regulations, guidelines on the use of information technology) promote respect for employee rights and are intended to prevent discrimination. A corresponding feedback culture (including through the annual employee appraisal discussions) has been established. AMAG also attaches great importance to the protection of personal data (Group-wide data protection guidelines, works agreements, data protection declaration).

For more informations, please see annual report 2021

Targets

Target 2021: 

  • Adherence to principles of human rights at AMAG and at its suppliers

Central measures:

  • The issue of human rights due diligence, particularly in the supply chain, has gained momentum in recent years. A European supply chain law, the preparation of which is progressing, sends a clear political signal in this context. This cross-industry set of rules aims to encompass social, environmental and human rights due diligence requirements within the supply chain. At the end of 2021, the EU Commission will present a legislative proposal on due diligence for the protection of human rights and the environment in the supply chain, and define a legal catalogue of criteria for companies’ due diligence obligations.
  • AMAG is already well positioned in this respect thanks to responsible procurement management, which was implemented in 2018 as part of ASI Performance Standard certification.
  • Responsibility for human rights as well as a human rights position were anchored within human rights training in 2021, which is imparted via the e-learning system. This training aims to raise internal awareness of human rights issues. Departments that deal with human rights issues – especially Human Resources, Sales, Purchasing and Communications – receive information and recommendations for action in relation to human rights both within AMAG and along the supply chain. 
  • In the course of a risk evaluation, key suppliers with which a business relationship exists were again assessed in 2021 and discussions were held with suppliers on the importance of ESG issues.  

2022 target / medium term:

  • Adherence to principles of human rights at AMAG and at suppliers by creation of a human rights brochure & involvement of AMAG components in responsible procurement management
Results

Results:

 

Any violation of human rights or applicable law can be raised via the compliance hotline. In 2021, no violations of human rights were reported by suppliers or employees. In the course of the risk assessment of key suppliers in the upstream supply chain (metal alloys, scrap, primary aluminium and rolling slabs), no suppliers were identified as high risk. More than 95 % of the procurement volume was purchased from low-risk suppliers.

Since the 2017 reporting year, we have published a summarized non-financial statement in our management report, thereby fulfilling our reporting obligation in accordance with the Sustainability and Diversity Improvement Act (NaDiVeG). It summarizes the essential information for AMAG on the five required aspects of environmental issues, employee issues, social issues, respect for human rights, anti-corruption and bribery.

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