Report - COP Prototype

2022 Communication on Progress

Raiffeisen-Holding NÖ-Wien

Published date

June 29, 2022

No. of questions

Supplemental files

Verhaltensgrundsätze.pdf Corporate-Governance-und-Vergütung.pdf Leitbild.pdf Lobbying-Verhaltenskodex-Lobby-26.07.2019.pdf 210906_raiffeisen-holding_noe-wien_un_global_compact_cop_2020_Version_Upload_Webseite.pdf SUSTAINABILITY REPORT 2020.pdf NFI-ERKLAeRUNG 2021.pdf Informationspflicht_Stand_03_2019.pdf Verhaltensgrundsätze.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

https://www.raiffeisenholding.com/wp-content/uploads/NFI-ERKLAeRUNG-2021.pdf

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Raiffeisen-Holding Niederösterreich-Wien works primarily with suppliers and business partners who support the corporate values of Raiffeisen-Holding Niederösterreich-Wien. Raiffeisen-Holding Niederösterreich respects the rights set out in the International Charter of Human Rights and recognizes the universality of human rights in all countries and cultures. (cit. Sustainability Report 2020, p. 15, 40, 50, 58 and COP 2020 p.2-3). Raiffeisen-Holding signed the Charta der Vielfalt (Diversity Charter) in April 2021: https://www.wko.at/site/Charta-der-Vielfalt/unterzeichnerinnen/unterzeichnerinnen-der-charta-der-vielfalt/UnterzeichnerInnen_der_Charta_der_Vielfalt.html

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Raiffeisen-Holding Uniform appointed a sustainability & CSR officer on 1 February 2020 to ensure that various procedures and the efficient implementation of the defined measures in the topics relevant will be followed through. The sustainability & CSR officer is part of the corporate communications / sustainability & CSR department and, consequently, reports to the General Manager. In addition, an inter-disciplinary panel of experts and senior managers with decision rights "Team N" serves as communication hub towards specialist departments and participate in the identification, development and implementation of relevant measures. Regarding Human Rights, Raiffeisen-Holding is teaming up with the Raiffeisen Sustianability Initiative to jointly develop a benchmark policy within a dedicated working group for later implementation alongside relevant procedures.

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Sustainability is an interdisciplinary issue that is under continuous development. Fast reaction is ensured because the chairman is responsible for principal decisions, the managing board and management are involved, and the supervisory board is regularly informed of current progress. The managing boards and business segments in both companies have each appointed a contact partner for sustainability management. As “Team N”, they serve as a communication hub between the sustainability & CSR officer and the specialist departments.

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

We assess all risks in compliance with BWG, CRR, EBA-Guidelines particularly on Loan Origination and the relevant EU directives and regulations such as SFDR, SFTR and in the near future also CSRD and CSDD. ESG is assessed in the downstream value chain.

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

In addition to safe and healthy working conditions, Raiffeisen-Holding Niederösterreich-Wien attaches particular importance to fair remuneration and employees' right to freedom of association and collective bargaining. ESG risks in our own operations and in the operations of our customers are being assessed at least once a year.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

We have a whistleblowing hotline in place where employees can raise any concerns regarding the company's conduct anonymously. In addition all management staff, internal audit and the works council are open for all questions and concerns employees may have.

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

The employees of Raiffeisen-Holding NÖ-Wien Gruppe are able, in agreement with legal requirements, to anonymously report internal violations of legal regulations (in accordance with §70 (4) of the Austrian Banking Act) and compliance rules. The Raiffeisen-Holding NÖ-Wien Gruppe has published an internal whistle-blowing policy (“Dienstanweisung zum Hinweisgebersystem/Whistle-blowing”) to meet this requirement, which regulates the handling of whistleblowing. This policy is available to all employees via the Intranet. Employees can report information on misconduct to the internal audit department directly (via email, letter etc.) or indirectly and anonymously via an external telephone hotline. This hotline is available in Austria 24 hours a day, seven days a week. Every employee receives a case number for his or her report and a pass word to access recorded responses or questions. The telephone conversation is followed within two working days by a written report (transcript of the anonymous information) to the head of internal audit for confidential investigation, who carries out an initial evaluation of the anonymous report and establishes the further procedures.

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Remediation Processes are in place for employees and customers.

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	3
Male (%)	66.6
Female (%)	33.3
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	33.3
Above 50 years old (%)	66.6
From minority or vulnerable groups (%)	0
Executive (%)	100
Independent (%)	0

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Third-party assurance is provided by our external auditor for our non financial-report.

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

The data protection framework is focussing on all activities where personal data are being processed. It consits of data protection service instructions, the manuel on data protection management system and other internal regulations, e.g. IT security guidelines and IT service instructions. The relevant internale regulations contain corresponding data protection goals and security guidelines.

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Raiffeisen-Holding NÖ-Wien is engaged in the Raiffeisen Sustainability-Initiative.

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Raiffeisen-Holding Niederösterreich-Wien and its most shareholding, Raiffeisenlandesbank Niederösterreich-Wien, informs the public on the website www.raiffeisenbank.at under ”security/current-alerts“ about current phising attacks. Raiffeisen customers are also being informed through our electronic banking app (ELBA). The protection of customer data is particularly important in the banking business. RLB NÖ-Wien views the protection of all data which it has received or can access – from customers as well as employees – with great importance as an integral part of its business activities. RLB NÖ-Wien meets the disclosure requirement for the collection of personal data on involved persons by publishing this information on the website www.raiffeisenbank.at under ”data protection“; this information is also available at the counters in the branch offices.
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Raiffeisen-Holding NÖ-Wien engages in the activities of Orange the World. Some of the shareholdings like NÖM also raise awareness through information on the products (In support of women threatened by violence, NÖM printed contact information for counselling services on their milk packages for sale in retail outlets.).

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Every company in the Raiffeisen-Holding Niederösterreich-Wien Konzern has appointed a data protection officer or manager or an external data protection coordinator to ensure the smooth handling of the related requirements. These persons are also responsible for the organization and coordination of regular training for employees.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

At the principal investment of Raiffeisen-Holding NÖ-Wien, the Raiffeisenlandesbank NÖ-Wien, 46 cases of concern regarding data privacy were raised in 2021, of which only 1 had to be reported to the data protection authority according to Art. 33ff of GDPR (General Data Protection Regulation). No incidendent regarding violations of women's or girls' rights was reported in 2021.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Raiffeisen-Holding NÖ-Wien is a founding member of the Raiffeisen Sustainability Initiative (RNI). Within the next two years, RNI and its members are strengthening their focus on human rights by working on a draft policy on human rights in 2021. For this purpose, a working group was implemented supported by a renowned academic institution with the aim on providing a policy compliant with the UN Guiding Principles on Business and Human Rights and the expected regulations on Corporate Sustainability Due Diligence.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2021
Forced labour
Raiffeisen-Holding Niederösterreich-Wien has set itself the goal of fully respecting human rights and sees them as the basis of corporate activity. In Austria, human rights are protected by the constitution and numerous laws, the European Convention on Human Rights has constitutional status. These rights form the fundamental legal basis for all our employees and thus protecting them by the three powers of the state and law enforcement, we do not see a demand for an additional formal corporate policy against forced labour.
Child labour
Raiffeisen-Holding Niederösterreich-Wien has set itself the goal of fully respecting human rights and sees them as the basis of corporate activity. In Austria, human rights are protected by the constitution and numerous laws, the European Convention on Human Rights has constitutional status. These rights form the fundamental legal basis for all our employees and thus protecting them by the three powers of the state and law enforcement, we do not see a demand for an additional formal corporate policy against child labour.
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
The Raiffeisen-Holding Niederösterreich-Wien Konzern sees healthy and motivated employees as the key factor for its successful development. The safety and protection of employees are taken very seriously in all invested companies and viewed as a priority. The operational activities of the Raiffeisen-Holding Niederösterreich-Wien are administrative activities and therefore there is only a marginal rest risk for accidents during work for all employees. The protection of health and safety are an important issue, above all for our invested producing companies, due to the health challenges that accompany production processes. Consequently, all these companies take a proactive and systematic approach to occupational safety and health. The responsibility is individually anchored in each company supervised by management, the human resources department and specialists like security experts and occupational physicians.
Working conditions (wages, working hours)
2021

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
in all Austrian operations the Freedom of association and the effective recognition of the right to collective bargaining is a legal right which we adhere to.
Forced labour
In all Austrian operations, child labour and forced labour are illegal and adherence to the respective law is enforced.
Child labour
In all Austrian operations, child labour and forced labour are illegal and adherence to the respective law is enforced.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Raiffeisen-Holding Niederösterreich-Wien and its most important investment, Raiffeisenlandesbank Niederösterreich-Wien, signed the Diversity Charter in April 2021. The charter’s goal is to advance the recognition, respect for and inclusion of diversity in the working world. Diversity is viewed as an interdisciplinary topic by the various departments and is the responsibility of the involved department or the management of the respective member company. Moreover, all departments and employees are called on to support diversity in their area of action. Managers are also responsible for undertaking suitable measures to counter possible thematic risks as part of their due diligence obligations. Raiffeisen-Holding Niederösterreich-Wien guarantees equal opportunities and equal treatment, regardless of ethnic origin, skin color, gender, disability, ideology, religion, nationality, social background, political attitude and political orientation.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

In addition to safe and healthy working conditions, Raiffeisen-Holding Niederösterreich-Wien attaches particular importance to fair remuneration and employees' right to freedom of association and collective bargaining. Every year legitimate sector representatives from the works council meet with management representatives to negotiate fair remuneration for all employees. COP 2020, page 4

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
In December 2021, the Raiffeisen-Holding Niederösterreich-Wien and the Raiffeisenlandesbank Niederösterreich-Wien appointed an Equal Treatment and Diversity Officer to make our appreciation towards all members of society visible and to establish a contact person for equal treatment, anti-discrimination and diversity issues in the company.
Occupational safety and health
The companies in the Raiffeisen-Holding NÖ-Wien Konzern quickly implemented preventive measures to address the outbreak of the corona pandemic in 2020. They included compulsory mouth-nose covering as well as disinfection stations and temperature measurement for employees via thermal imaging camera. Free COVID test stations were installed at the Raiffeisenhaus Wien and in the branch offices, which are available to employees on a voluntary basis.
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
legal requirement in Austria.
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)
An employees membership in a trade union belongs to the persons private data and is subject to the EU General Data Protection Regulation (GDPR), therefore this data is not collected.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	30
Non-executive board	22

Optional comment

In our sustainability reporting (Non-Financial Report) 2021 we count all managerial levels (management board, head of division, head of department, team leaders). For this COP 2021 the number of senior leadership level consists of the number of board member and head of division.

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
Data collected in certain shareholdings, findings not representative due to sector specific categorization of job profiles.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0

Optional comment

1 documented injury in 1.83 mn working hours

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Based on the business continuity management concepts, the management of Raiffeisen-Holding Niederösterreich-Wien and Raiffeisenlandesbank Niederösterreich-Wien established a crisis staff in the form of the health protection team at the beginning of 2020. Also, during 2021 this team supplied employees with regular information on planned measures and served as a contact point for questions related to COVID-19. The Raiffeisen-Holding Niederösterreich-Wien Konzern offers a wide variety of preventive measures to promote and protect the health of its employees. All legally required measures for health protection are obviously met and, in addition, the member companies of the Raiffeisen-Holding Niederösterreich-Wien Konzern have developed additional health-related programmes for their employees. They range – depending on the company – from flexible working time models, company day-care centres and medical check-ups to subsidies for supplementary health insurance and sport opportunities. The Life Balance Center at the headquarters in Vienna bundles the extensive offering for health, sport and family and provides information and assistance for the employees of the Raiffeisen-Holding Niederösterreich-Wien Gruppe. Since 2004, the Raiffeisen-Holding Niederösterreich-Wien has carried the “berufundfamilie“ state quality seal which is awarded by the Federal Ministry for Women, Family and Youth. This seal has also been awarded to the most important subsidiary of Raiffeisen-Holding Niederösterreich-Wien, Raiffeisenlandesbank Niederösterreich-Wien, we looking forward to its recertification in 2022.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
Water is not a material issue for the Raiffeisen-Holding Niederösterreich-Wien as we operate regionally in the landlocked country Austria.
Oceans
Oceans are not a material issue for the Raiffeisen-Holding Niederösterreich-Wien as we operate regional in the landlocked country Austria.
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2020 "Waste Management Concept" according to Section 10 of the Waste Management Act 2002
Energy & Resource Use
2021

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Climate Action and Energy & Resource matters were developed with the Austrian Environment Office (Umweltbundesamt)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

The involvement of stakeholders, i.e., those people and groups of people who have legitimate interests and influence in connection with direct or indirect business activities, is an integral part of the business processes. For this purpose, specific dialogue and event formats are used to exchange ideas with stakeholders. Due to strict COVID-19 security measures in 2021, these took place primarily as virtual or hybrid events. The stakeholder survey at the beginning of 2021 and the insights gained from it were incorporated into a strategy process. The aim was to integrate sustainability aspects and define the sustainable positioning in the corporate strategy.

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
According to the Waste Management Act 2002, waste volumes are monitored and reported.
Energy & Resource Use

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

423.5

Scope 2 Emissions

Full

None

Emissions (tCO2e)

2240.648

Scope 3 Emissions

Full

Partial

None

The company's gross global greenhouse gas emissions for the reporting period were not measured.

Emissions (tCO2e)

Optional comment

In 2021, Raiffeisen-Holding NÖ-Wien and its most important shareholding, Raiffeisenlandesbank NÖ-Wien collected data on scope 1 and 2 on the basis of both 2019 and 2020 to assess the status for our decarbonisation pathway.

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

electricity from water divided by total energy consumption

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

0.6

The share of revenues that can be identified as taxonomy eligibile revenues (approx. 0.6%) is relatively small, since relevant sales revenues from our industrial subsidaries have little relevance in the current state of taxonomy regulation. With respect to Raiffeisenlandesbank NÖ-Wien, the most important sharholding, the taxonomy eligibility ratio is 8,7%.

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Sustainability is part of our identity and an essential part of our corporate development. Today we implement this value in a contemporary way. Because we know that only sustainable solutions create real added value for people, society, the environment and institutions. We are actively committed to climate protection, not only as part of our own economic activities and operational environmental protection, but also as part of the Raiffeisen Sustainability Initiative. Raiffeisen-Holding Niederösterreich-Wien and Raiffeisenlandesbank Niederösterreich-Wien have had an ecological footprint assessed in 2021 by the Austrian Federal Environment Agency for the years 2019 and 2020 commissioned. Its results are, among other things, also the basis for the further decarbonisation path in the operational environmental protection. A first measure is the new electricity procurement contracts concluded with NATURKRAFT in 2021 for the years 2024 and 2025. The electricity has been awarded with the Umweltzeichen 46 and comes exclusively from certified Austrian power plants (small hydropower, biomass, wind and photovoltaics). In terms of operational ecology, the companies focus on energy efficiency and resource conservation, climate-friendly mobility, selecting suppliers that are as regional as possible, and the procurement of environmentally friendly office and cleaning products. In order to promote the reduction of CO2 emissions from the Raiffeisen-Holding fleet and its most important subsidiary, Raiffeisenlandesbank Niederösterreich-Wien, a new company car guideline was drawn up and put into effect at the end of 2021 - the focus is on electrically powered vehicles and vehicles with low CO2 emissions. In addition greenery was planted on suitable roof areas in 2021 in order to improve the microclimate at the locations. Raiffeisen-Holding Niederösterreich-Wien is examining the implementation of necessary measures in connection with the topic of climate protection in the reporting year and will continue to pursue these with high priority in the 2022 financial year.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

The Programme in its current format is regularly reviewed and focuses on all members on staff. Detailed procedures are in place for invitations & gifts, events, advertisements, donations and sponsorships and a strict Code of Conduct to avoid conflicts of interest, insider trading and market abuse. Regular trainings and awareness are being provided by Compliance and HR, Compliance is also involved in measures that are suitable to mitigize misconduct and in investigations of infringements.

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

All employees of Raiffeisen-Holding Niederösterreich-Wien and its most important shareholding, Raiffeisenlandesbank Niederösterreich-Wien, have knowledge about corruption prevention (e.g. manual, guidelines). Select members of staff renew their trainings every year, all members of staff are required to renew their trainings every third year. In 2021, approx. 87% of the staff actively completed specific anti-corruption trainings.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Internal audits by specialised department

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
There were no confirmed cases of corruption in the Raiffeisen-Holding Niederösterreich-Wien Konzern during 2021, and no employees were terminated or reprimanded due to corruption.
Confirmed during the current year, and related to this year	0
There were no confirmed cases of corruption in the Raiffeisen-Holding Niederösterreich-Wien Konzern during 2021, and no employees were terminated or reprimanded due to corruption.

Optional comment

The prevention of corruption means respect for the rules of law in keeping with ethical standards. Corruption undermines an organization‘s ability to function as well as its moral authority and exposes the company or persons to prosecution under civil and administrative law. The business processes in Raiffeisen-Holding Niederösterreich-Wien and its investments therefore contain extensive rules for conduct and requirements. To prevent conflicts of interest for employees, the Raiffeisen-Holding Niederösterreich-Wien Konzern has defined strict framework conditions for secondary employment. Paid and unpaid activities must be reported and approved and, in certain cases, are reviewed in detail by human resources and compliance officers.

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Raiffeisen-Holding Niederösterreich-Wien and its investments support the implementation of ethical standards of behaviour as the basis for fair operating and business practices as well as the prevention of corruption. The employees of Raiffeisen-Holding Niederösterreich-Wien Gruppe are able, in agreement with legal requirements, to anonymously report internal violations of legal regulations (in accordance with §70 (4) of the Austrian Banking Act) and compliance rules. The Raiffeisen-Holding Niederösterreich-Wien Gruppe has put in place a whistle-blowing regulation (“Dienstanweisung zum Hinweisgebersystem/Whistle-blowing”) to meet this requirement, which regulates the handling of whistle-blowing. This guideline is available to all employees in the Intranet. Employees can report information on misconduct to the internal audit department directly (via email, letter etc.) or indirectly and anonymously via an external telephone hotline. This hotline is available in Austria 24 hours a day, seven days a week. Every employee receives a case number for his or her report and a password to access recorded responses or questions. The telephone conversation is followed within two working days by a written report (transcript of the anonymous information) to the head of internal audit for confidential investigation, who carries out an initial evaluation of the anonymous report and establishes the further procedures.