UBM Development AG has had a group-wide issuer compliance guideline in place for years. The guideline contains principles for the disclosure of information, defines measures to prevent the misuse of insider information and regulates everything that ensures compliance with the relevant legal provisions and avoids conflicts of interest. Ongoing adjustments to changes in legal requirements are a matter of course. The compliance officer monitors adherence to all guidelines. UBM acts responsibly and does this, among other things, through transparent internal guidelines and rules of conduct, as well as the commitment to various corporate governance regulations. Based on our corporate values and the UBM Code of Ethics, the Compliance Organization has the task of ensuring the implementation of internal guidelines (e.g. corruption guidelines), conduct in compliance with the law and adherence to the ÖCGK Austrian Corporate Governance Code through the Compliance Management System (UBM-CMS).

As a listed company, UBM Development AG also complies with all provisions of the Stock Exchange Act and the EU Market Abuse Regulation („MAR“), which has been in force since July 3, 2016. This task represents an essential part of the compliance function and organization.

The compliance management system is continuously monitored through risk analyses, reviews and internal audits. Any violations are corrected.

In order to strengthen the trust of employees, business partners, customers and other stakeholders, UBM focuses on transparency, anti-corruption, fair business practices, money laundering prevention and data protection.

In the area of money laundering and terrorist financing prevention, comprehensive audit processes are implemented on the basis of internal risk analyses.

As the Managing Board of UBM Development AG is very much aware of its responsibility in the fulfilment of all compliance tasks and pays particular attention to the observance of all legal requirements in this regard as well as the internal issuer compliance guidelines, UBM Development AG is constantly and intensively concerned with reminding employees of compliant behavior and preventing insider misconduct. The establishment of the necessary problem awareness at UBM Development AG is being intensively promoted by the Managing Board. Training courses for employees are held on a regular basis. The aim of the training is to make employees aware of possible sources of risk and thus to prevent corruption, anti-competitive behavior, market abuse, insider trading, money laundering and misuse of data.

UBM Development AG has

  • an issuer compliance guideline
  • a compliance management system (manual)
  • a guideline for the prevention of corrupt behavior
  • an antitrust and competition law guideline
  • a guideline on the prevention of money laundering and terrorist financing
  • a guideline on the conduct of employees in the event of official searches of offices
  • a code of ethics
  • a code of conduct for business partners
  • a guideline on the compulsory process for conflicts of interest
  • a data protection guideline, a data protection compliance manual, a data protection violation and duty to inform guideline, a data storage and data deletion guideline
  • a procurement guideline
  • a whistleblower system in accordance with Art. 32 MAR
  • an internal monitoring system

The Deputy Compliance Officer, Serena Holoubek, is a certified compliance officer in accordance with the international standard ISO 19600 and the Austrian standard ONR 192050 issued by Austrian Standards, as well as a certified money laundering compliance expert.

Whistleblower system – notification in accordance with Art. 32 MAR

With this whistleblower system, both employees of UBM Development AG and third parties have the opportunity to anonymously report violations of the issuer compliance guidelines, in particular market abuse, insider trading, other violations in connection with issuer compliance, violations of data protection regulations, money laundering and terrorist financing, other reporting offences in accordance with EU Directive 2019/1937 and other reports in connection with the UBM Code of Ethics.

It is expressly noted that only actual and suspected violations can be reported using this whistleblower system. A suspected breach or indications of a violation should only be reported if the allegations are based on the whistleblower’s own personal perception, are considered to be significant to the best of the whistleblower’s knowledge and belief, and appear to be justified with a high degree of probability.

Deliberate false reports will result in consequences under labor and criminal law.

Link to whistleblower system:

compliance officer.

Ralf Mikolasch
Legal & Compliance Ralf Mikolasch