OMV uses the following metrics to evaluate its performance and effectiveness: [MDR-M.77a, 77c-77d] [G1-3.21b] [G1-4.22, 24a] [G1-4.25a-25c]

In-person trainings 2024:

  • 39% of functions at risk currently covered in the ongoing training cycle for the in-person business ethics/anti-corruption training program.
  • 38% of functions at risk currently covered in the ongoing training cycle for the in-person competition law training program.

E-Learning program 2024:

  • 95% of functions at risk covered in the e-learning program on competition law.

0[G1-4.24b] Including Borealis. As we had no convictions for violation of anti-corruption and anti-bribery laws in 2024, no actions to address breaches in procedures and standards of anti-corruption and anti-bribery were applicable. convictions for violation of anti-corruption and anti-bribery laws

EUR 0 mn in fines for violation of anti-corruption and anti-bribery laws

0 confirmed incidents of corruption or bribery

0 confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents

0 confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery

[Voluntary] 60Excluding Borealis whistleblowing cases in the OMV Group brought to the attention of the Compliance department via OMV’s whistleblowing mechanisms

Business ethics/anti-corruption training (in-person)

[G1-3.21b] [G1-3 AR-8] [MDR-M.77c]

 

 

2024

 

 

At-risk functions

Managers

Administrative Management and Supervisory Bodies (AMSB)

Other own workers

Training coverage

 

 

 

 

 

Total target group

number

920

723

59

n.a.

Total receiving training in the year 2024

number

357

344

22

844

Delivery method and duration

 

 

 

 

 

Classroom training

hours

1

1

1

1

Computer-based training

hours

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

hours

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

 

How often training is required

 

Three-year training cycle

Three-year training cycle

Three-year training cycle

n.a.

Topics covered

 

 

 

 

 

Definition of corruption

 

x

x

x

x

Policies (Code of Business Ethics, Ethics & Integrity Policy, Whistleblowing Directive)

 

x

x

x

x

Procedures regarding prevention and detection of corruption and bribery

 

x

x

x

x

Protection of whistleblowers

 

x

x

x

x

Competition law training (in-person)

[G1-3.21b] [G1-3AR 8]

 

 

2024

 

 

At-risk functions

Managers

Administrative Management and Supervisory Bodies (AMSB)

Other own workers

Training coverage

 

 

 

 

 

Total target group

number

642

209

38

n.a.

Total receiving training in the year 2024

number

245

73

17

51

Delivery method and duration

 

 

 

 

 

Classroom training

hours

1.5

1.5

1.5

1.5

Computer-based training

hours

n.a.

n.a.

n.a.

n.a.

Voluntary computer-based training

hours

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

 

How often training is required

 

Three-year training cycle

Three-year training cycle

Three-year training cycle

n.a.

Topics covered

 

 

 

 

 

Horizontal relationships/cartels

 

x

x

x

x

Vertical relationships

 

x

x

x

x

Abuse of dominance

 

x

x

x

x

Dawn-raid procedures

 

x

x

x

x

Competition law training (e-learning program)

[G1-3.21b] [G1-3AR 8]

 

 

2024

 

 

At-risk functions

Managers

Administrative Management and Supervisory Bodies (AMSB)

Other own workers

Training coverage

 

 

 

 

 

Total target group

number

858

201

27

n.a.

Total receiving training in the year 2024

number

811

188

23

n.a.

Delivery method and duration

 

 

 

 

 

Classroom training

hours

n.a.

n.a.

n.a.

n.a.

Computer-based training

hours

0.75

0.75

0.75

n.a.

Voluntary computer-based training

hours

n.a.

n.a.

n.a.

n.a.

Frequency

 

 

 

 

 

How often training is required: OMV

 

Bi-annually

Bi-annually

Bi-annually

n.a.

Topics covered

 

 

 

 

 

Horizontal relationships/cartels

 

x

x

x

n.a.

Vertical relationships

 

x

x

x

n.a.

Abuse of dominance

 

x

x

x

n.a.

Dawn-raid procedures

 

x

x

x

n.a.

Metrics Definitions and Methodology

[MDR-M.77b] The measurement of all metrics below is not validated by an external body other than the assurance provider.

[G1-21b] [MDR-M.77a, 77c] The percentage of functions at risk covered by training programs is calculated as follows: the number of employees (full-time and part-time) who have attended training programs divided by the total number of employees identified in the target group for training programs, multiplied by 100.

[G1-4.22, 24a] [MDR-M.77a, 77c] The number of convictions for violations of anti-corruption and anti-bribery laws is counted on a case-by-case basis for these specific violations.

[G1-4.24a, 24c-24d] [MDR-M.77a, 77c, 77d] Fines in EUR mn for violations of anti-corruption and anti-bribery laws is based on the total amount of fines received for these specific violations.

[G1-4.25a] [MDR-M.77a, 77c] The number of confirmed incidents of corruption or bribery refers to cases where an employee verifiably gives, agrees to give, promises or offers a financial advantage to another person to obtain business with OMV or a third party.

[G1-4.25b] [MDR-M.77a, 77c] The number of confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents refers to cases where an employee verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business for OMV.

[G1-4.25c] [MDR-M.77a, 77c] The number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery refers to incidents whereby a business partner verifiably gives, agrees to give, promises, or offers a financial advantage to another person to obtain business with OMV or a third party.

[Voluntary] The number of whistleblowing cases in the OMV Group refers to the number of reports regarding alleged misconduct/breach of law or internal regulations brought to the attention of the Compliance department via OMV’s whistleblowing mechanisms.

[G1-3.21b] [G1-3 AR 8] [MDR-M.77c] Table on business ethics training (in-person training and/or e-learning)

  • Total receiving training in the year 2024 refers to the total number of employees that completed the in-person and/or e-learning business ethics training.
  • Voluntary computer-based training: the term “voluntary” refers to training that is not mandatory in the reporting cycle.

[G1-3.21b] [G1-3 AR 8] [MDR-M.77c] Table on competition law training (in-person training and/or e-learning)

  • Total receiving training in the year 2024 refers to the total number of employees that completed the in-person and/or e-learning competition law training program.

Borealis

G1 – Borealis Business Ethics and Anti-Corruption and Anti-Bribery

[G1-3.21b] [G1-3 AR-8] [MDR-M.77c]

 

At-risk functions 2024

Training coverage

 

Total

537

Total receiving training

166

Delivery method and duration

 

Classroom training (hours)

n.a.

Computer-based training (hours)

0.5

Voluntary computer-based training (hours)

n.a.

Frequency

 

How often training is required

Annually

G1 – Borealis metrics to evaluate its performance and effectiveness

[MDR-M77a]

Metric and definition

Unit

Methodology

2024

Percentage of Borealis employees completing the e-learning on the Borealis Ethics Policy

%

The number of Borealis employees who complete the training as a percentage of the number of Borealis employees assigned to the training.

85

The number of ethics reports filed through the whistleblower hotline by Borealis’ own workforce

Number

The data is sourced from EQS, the external service provider for the Borealis whistleblower hotline. Non-substantiated cases are counted, unless the reported grievance obviously does not violate the Borealis Ethics Policy.

62

The number of non-compliances or recommendations from recertification or surveillance audits based on ISO 37301/37001

Number

The external auditor pursues the mandatory annual audit of Borealis AG. Thereafter, a report is issued and shared, in which each instance of non-compliance is described

2

[MDR-M77b] The number of instances of non-compliance or recommendations from recertification or surveillance audits based on ISO 37301/37001 is validated by the Austrian Standards certification body. The ISO certificates can be downloaded from the Borealis website: www.borealisgroup.com. For more details, see Borealis Group Annual Report 2024 – Group Management Report – Non-financial Statement.

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