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Sustainability report 21|22

Fairness and transparency

Long-term, stable business relationships with contractual partners and suppliers are particularly important to us, and we are well-known for the long-standing ties we forge. These relationships are characterised by fairness, trustworthiness, integrity and transparency. We take transparent decisions that we communicate clearly to our suppliers and customers. We are committed to upholding the principles of fair and honest competition, and complying with all statutory regulations designed to combat bribery and corruption.

Fair competition

RAG operates under varied and constantly changing social, political and economic conditions. We believe that society’s interests are best served by the free market. We set out to compete fairly and responsibly, and in conformity with current competition law. RAG will not take any steps designed to stop companies competing against it. This is also embedded in our policies.

We do not conclude anti-competitive agreements and do not exploit our market position as a leading domestic energy storage company. We are committed to living up to our responsibility to reliably deliver energy to Central European energy suppliers and their customers, as this is the only way to secure the basis for cost-effective energy use by private households and industry. 
 

Likewise – and irrespective of the various statutory regulations we are required to comply with – we reject practices such as bid rigging and price fixing as a matter of principle. The company trades energy either on publicly accessible exchanges or bilaterally on the basis of contracts.

In terms of mineral oil and natural gas production, long-term agreements with local suppliers and refineries ensure steady business relationships to the greatest possible extent. For financial reasons, prices are tied to free market conditions, meaning that commercial developments are subject to price fluctuations on the oil and gas market, and are not within our control.

We take steps to continuously expand our expertise on the topic of fair competition by comparing notes with experts at related events organised by the Austrian Federal Economic Chamber, as well as by reviewing specialist publications and announcements from organisations including Transparency International, and applying them internally where appropriate.

Unbundling RAG Energy Storage (RES)

The statutory unbundling of RAG – a natural gas producer and technical storage operator – and storage marketing business RAG Energy Storage (RES) has contributed substantially to the consolidation of fair competition on the Austrian energy market. Compliance with the ban on discrimination and the requirements for equal treatment in dealings with storage customers are monitored by the Anti-Discrimination Officer at RES. Relevant technical information for storage customers is reported and published in accordance with the applicable EU regulations, in particular the REMIT Regulation.

As part of an internal audit, in 2021 the Internal Audit Department carried out a review of the equal treatment of RES customers as set out in the unbundling regulations and found absolutely no evidence of discrimination.

The following specialist departments are primarily responsible for taking effective measures designed to prevent anti-competitive practices at RAG:

Procurement:

  • Procurement Department
     

Sales:

  • Gas storage – RES (marketing business for storage capacity)
  • CNG, LNG – Midstream Department (filling station operator)
  • Mineral oil tank farms – Midstream Department
  • CHP plants – Midstream Department
  • Gas trading – Energy Trading Department
  • Services – Business Development
  • Financial subsidies – respective specialist department, Controlling
     

Anti-corruption measures

Unethical practices are not consistent with our value system and, in any event, run contrary to the principles of economic and sustainable development. Our employees are forbidden from requesting or accepting preferential treatment or inducements, and from offering or providing such advantages to others. They are also obliged to avoid conflicts of interest between personal matters and their company-related duties. In order to prevent misconduct, all employees receive compulsory training on appropriate behaviour. The company also has internal anti-corruption reporting systems in place, and reports are prepared annually for the Executive Board and the Audit Committee. Employees who wish to report misconduct or breaches of the law can do so through our whistleblowing system, which is operated as an external platform. This enables us to prevent unethical behaviour at an early stage. Internal stakeholders can also raise their concerns with the works council, safety officers and data protection officers. During the period under review, no cases of misconduct or significant breaches of laws or regulations were reported. 

Donations and sponsorship of third parties require the express permission of the Executive Board. All such activities are registered centrally and reported to the Executive Board and the Audit Committee once a year. The related documents are also disclosed to the auditor.

RAG Austria AG has no political affiliations and makes no financial contributions to political parties or organisations, or their representatives. We represent RAG’s interests in dealings with public bodies with regard to matters that affect the company itself, its employees or customers, and representatives of the owners. This is done with the utmost transparency through memberships or involvement in working groups set up by various industrial associations and interest groups. These include P&G Wasserstoffinitiative Vorzeigeregion Austria Power & Gas (Hydrogen Initiative Flagship Region Austria Power & Gas, WIVA P&G), of which RAG is a founding member. 

All of our facilities are located in Austria, where the risk of corruption is classified as not very high (CPI 2022: 71/100)*. RAG has no operations in countries which have high corruption index scores. Internal guidelines and training help to prevent corrupt behaviour, and an internal reporting system for gifts and inducements received and offered transparently records the instances concerned.

Corruption risk is assessed internally on an annual basis using a one-step model. Where necessary, Internal Audit can carry out targeted investigations.

*Corruption Perception Index of Transparency International