UBM Development AG has already had a Group-wide applicable emitter compliance guideline for many years. The guidelines specify basic principles for disseminating information, provide key measures to avoid insider trading and regulate everything to guarantee legal compliance and avoid conflicts of interests. Naturally, the guidelines are regularly updated to conform to any changes in the law. The compliance officer is responsible for monitoring adherence to all guidelines.
On the basis of our corporate values and UBM’s ethics codes, the compliance organisation is tasked with implementing internal guidelines (e.g. anti-corruption guidelines) to ensure behaviour that conforms to the law as well as adherence to the Austrian Code of Corporate Governance through the Compliance Management System (UBM CMS).
Furthermore, as a listed company UBM Development AG upholds all of the provisions of the Stock Exchange Act and the Market Abuse Regulation (“MAR”) valid in the EU since 3 July 2016. This represents a significant part of the compliance function and organisation.
UBM Development AG has
- Issuer Compliance Guidelines
- a Compliance Management System (handbook)
- Guidelines to prevent corrupt behaviour
- an array of other guidelines and work instructions
- a whistleblower system in acc. with Art. 32 MAR
- Multi-year training plans for Group employees
Whistleblower System – Announcement in acc. with Art. 32 MAR
Reference is expressly made to the fact that, when using the whistleblower system that is in place, it is only possible to report actual and suspected infringements. A suspected breach or indication of an infringement should only be reported when the allegations are based on one’s own personal perception; the person making the report should be acting to the best of his/her knowledge and in good faith and there should be a high probability that he/she will prove to be justified.
Any case of deliberately making a false report shall incur consequences under labour and penal law.