Compliance at Vossloh

Compliance, as the sum of all Group-wide measures to comply with the legal and regulatory framework and internal guidelines, is a key management and control task at Vossloh. Doing business according to sustainable economic, social and ecological criteria is a central element of corporate culture for Vossloh. Vossloh sees the foundation for a successful future in the competence, quality and innovative strength of the Company, as well as the long-standing trust of its business partners. An essential precondition for this success is Vossloh's integrity in its dealings with employees, business partners, stockholders and the general public.

Vossloh AG’s Executive Board has unambiguously expressed its zero-tolerance policy regarding any infringements against law and order ( Mission Statement ). Any misconduct is rigorously pursued within the context of the applicable regulations.

In order to ensure uniform exemplary conduct, a code of conduct has applied to the entire Group and all its employees since 2007. In conjunction with the supplementary guidelines which also apply across the entire Group, this represents a framework which sets out binding principles and standards for all of Vossloh’s employees in addition to the statutory regulations. There are also references to typical situations, which provide advice to employees in terms of the right moral conduct in their daily work.

The compliance guidelines have been published in 15 languages and have been distributed to all employees in the Vossloh Group worldwide. All employees who have contact outside the Company are instructed using eLearning programs and in regular class training events. Country-specific features are included in supplementary policies which, however, are always built on the generally applicable policies of the Vossloh Group as a minimum standard. It is the duty of the compliance organization, the management and the executives to communicate compliance as a sustainable value and to anchor it into the Group structure. It ensures that the compliance program is implemented worldwide.

The Vossloh Group has an appropriate compliance organization, comprising a Chief Compliance Officer and employees at the level of Vossloh AG and other internal managers appointed as local Compliance Officers in the Group companies. These individuals are available to advise their colleagues on matters concerning conduct. Compliance Officers regularly report to the central Compliance Committee, which is established at the level of Vossloh AG. This body continually observes further developments and changes in the risk structure and adapts the internal compliance policies accordingly. The Chief Compliance Officer and the Compliance Committee also perform regular audits without grounds, mostly with external auditors, to verify the effectiveness and the efficiency of the compliance system, new and changed risks and to identify any areas for improvement. The Chief Compliance Officer regularly reports to the Executive and Supervisory Boards in addition to the Audit Committee of the Supervisory Board, which is in charge of compliance.

In addition, Vossloh, together with an international law firm, has appointed “ombudspersons”, who are contact persons for indications of potential compliance violations. The languages spoken in the Vossloh Group are largely covered. This means that Vossloh employees and external whistle blowers have the possibility to turn to these ombudspersons in their native language. Ombudspersons take the necessary measures to clarify the matter in advance so that the information can be followed up. For employees or external whistle blowers, the possibility exists that their names can remain anonymous to the respective company, but an efficient and successful resolution of the issue is nevertheless made possible.