Compliance at Vossloh

Vossloh considers compliance to be conduct in line with all the applicable laws and internal guidelines. As a global enterprise with an approximately 135-year history, Vossloh has a social responsibility toward its customers, partners, employees, investors and the public. This social responsibility involves Vossloh and all its employees adhering to the applicable laws, respecting basic ethical values and acting in an exemplary fashion at all times and in all situations in the course of their work.

The Management Board of Vossloh AG has explicitly expressed these principles in its Compliance Commitment, including: “Compliance with the law has absolute priority over closing a deal or achieving internal targets. We would rather forgo a business opportunity than violate the law. We will not tolerate any violation of the law or of our internal guidelines and policies and will sanction any such behavior (zero tolerance policy).”

The Management Board of Vossloh AG has established a Compliance Management System for the Vossloh Group. The Vossloh Compliance Management System is designed to identify risks of events of non-compliance and minimizing these risks by taking the appropriate steps to prevent damage risks for Vossloh and its employees. Prevention of corruption and the strict observance of antitrust regulations play a particularly important role.

Since 2007, the Vossloh Compliance-Management-System has been based on the Vossloh Code of Conduct, which stipulates and precisely defines the values of integrity and upstanding business conduct and is mandatory for the entire Group and all employees. The Code of Conduct was comprehensively revised and enhanced in 2016. With this and the compliance guidelines, which apply equally throughout the Group and were likewise revised in 2016, all the employees have a canon of rules that serves as a yardstick for their daily work and helps them make good and lawful decisions. The compliance rules are available in the Group’s main languages and have been distributed to all Vossloh Group employees around the world. Based on a compliance training concept, all the employees receive regular training on compliance issues that is tailored to the target group in question. Vossloh has also established a compliance e-learning program for all employees with a computer workstation.

To implement and monitor compliance, the Executive Board established the Compliance Organization, stipulating its structure, the responsibilities and tasks of the individual compliance positions, and their reporting channels in the “Rules of Procedure of the Compliance Organization.” The Vossloh Compliance Organization comprises the Chief Compliance Officer (supported by a Compliance Office), the Group Compliance Committee at Vossloh AG, Compliance Officers and Compliance Committees within the business units and Local Compliance Officers within the operating companies. The Chief Compliance Officer regularly reports to the Executive Board and Supervisory Board.

Together with an international law firm, Vossloh has established a whistleblower hotline to uncover potential Compliance violations. The whistleblower hotline gives employees and external whistleblowers an independent external contact (the ombudsperson) to report suspicions of potential misconduct. The whistleblower hotline is currently available for 24 countries, covering the most important regions and languages of the Vossloh Group. The Chief Compliance Officer follows up all reports and introduces appropriate measures, where necessary. The same applies for reports which employees can make internally. Employees can contact the Compliance Office directly.

The Chief Compliance Officer and the Group Compliance Committee continually review the effectiveness throughout the Group of the Compliance-Management-System. In the 2017 fiscal year, the Vossloh Group’s Compliance-Management-System was subjected to a comprehensive audit in accordance with Assurance Standard 980 of the Institute of Public Auditors in Germany (IDW) (IDW AsS 980) by KPMG AG Wirtschaftsprüfungsgesellschaft regarding the subsections of antitrust law and anticorruption. The audit (report only available in German) was performed as an effectiveness assessment and was concluded in February 2018. KPMG confirmed that the Vossloh Group’s Compliance-Management-System is implemented appropriately and was effective in the period under review.

Observations or recommendations for the future Compliance procedures have already been and are still being implemented in the course of the continuous further development and improvement of the Vossloh Compliance Management System.

The Group Compliance Committee also carries out regular audits, generally with the support of external auditors, in order to review the effectiveness of the Compliance Management System in the Group companies and to identify new or changed risks as well as potential opportunities for improvement.

If you have questions, suggestions or would like to make a notification with regard to the Vossloh Compliance Management System, please contact the Compliance Office of Vossloh AG:

Phone: +49 (0)2392 /52-723