Social commitment and compliance

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The Group’s Chief Compliance Officer and General Counsel speaks for this area on the Implenia Executive Committee. He reports here and at every meeting of the Audit Committee on company compliance issues. He is supported by the Global Head of Compliance & Data Protection. Her department is responsible for, among other things, implementing the compliance management system. Country Compliance Officers and Data Protection Coordinators and Officers are responsible for regional compliance issues in each country. They act as first points of contact for questions about legal and regulatory compliance and they receive initial reports of suspected irregularities. Together, they ensure that Implenia’s compliance standards are consistently applied across all markets.

Following the introduction of the revised “How We Work” Code of Conduct in 2023, all technical-commercial staff completed a mandatory e-learning programme on the content of the Code. This training programme also forms part of the new employee onboarding process to ensure a consistent understanding of core values and compliance obligations from the outset. In addition, regular training sessions are held on key legal and ethical topics such as competition law, conflicts of interest and corruption prevention. These measures strengthen everyone’s commitment to a Group-wide compliance culture.

In 2024, all technical-commercial staff completed e-learning courses on a variety of compliance issues. Of these, over 5,000 employees took part in Code of Conduct training, around 3,000 completed an e-learning course on data protection, and around 2,000 completed a course on competition law. As well as the e-courses, in-person training was held at local and Group meetings, and tailored training sessions were delivered at offices and on construction sites.

To keep the principles of the Code of Conduct in the forefront of people’s minds, Implenia regularly carries out awareness-raising campaigns. The launch of the revised Code of Conduct was accompanied by an internal communication campaign, for example, which was recognised by an INKOMETA Award in the “Campaigns” category in 2024. Further awareness-raising measures addressed, among other things, the way to handle gifts and invitations. Common questions, such as rules of conduct at trade association meetings, video surveillance on construction sites and dealing with conflicts of interest, are covered in the “Quick Guides” that Implenia has developed for employees.

The first internal Compliance Day was held in 2024. External specialists gave talks to more than 100 participating employees about important and Group-relevant compliance issues.

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If Implenia is implicated in investigations or lawsuits relating to competition law, it cooperates fully with the authorities and provides transparent information about the matter concerned. Since 2010, a total of five official investigations have taken place, two of which were completed some time ago. Implenia dealt with three outstanding cases during the period under review, two of which are still being investigated. 

• In Switzerland, the Competition Commission carried out several investigations between 2010 and 2019 in Canton Grisons. These concerned suspicions of illegal collusion in the road construction market as well as in building construction and civil engineering prior to 2010. Implenia gave the Competition Commission its unreserved cooperation throughout the process and helped to clear up the agreements on price and territories that were being investigated. The investigating authorities therefore refrained from imposing a fine on Implenia in the main investigation. The main investigation was subsequently divided into several sub-inquiries. In two of these, the Competition Commission refused to recognise Implenia as a principle witness and imposed fines for alleged collusion on two smaller building projects. Implenia appealed to the Federal Administrative Court against this refusal, and against the division of proceedings. This appeal was dismissed, so Implenia appealed to the Federal Supreme Court, where the case is still pending.
• In Austria, the Central Public Prosecutor’s Office for Combating Economic Crime and Corruption in Vienna has been conducting an investigation into suspected collusive bidding since 2017; Implenia Baugesellschaft GmbH is one of the companies it is looking at. The investigation is still under way.
• In March 2024, the Swiss Competition Commission broadened its investigation into possible collusion in civil engineering and building construction in Canton Neuchâtel, which was originally launched in November 2023. The investigation was extended from the original three to 19 companies, including Implenia. The Commission is investigating whether these companies colluded on offers and pricing for around 100 civil engineering tenders put out by public and private clients between 2009 and 2024. Implenia has assured the Competition Commission of its full cooperation.

Information on older cases can be found in previous Sustainability Reports.

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Respect for human rights is a central concern for Implenia as it seeks to meet its corporate responsibilities. Its commitment here is based on the United Nations Universal Declaration of Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work. In its Policy Declaration Implenia pledges its respect for, among other things, internationally recognised human rights and commits to uphold them in its business activities along the entire value chain.

Implenia has also pledged to comply with the following international conventions:

• United Nations Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• The International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work and its follow-up declaration
• Ten principles of the UN Global Compact
• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises

Implenia has implemented the following due diligence procedures to stop or redress human rights violations within its supply chain:

• Internal, global purchasing rules require that human rights and selected environmental criteria are applied when choosing and evaluating suppliers; self-declarations are required from suppliers to confirm they are meeting country-specific legal standards
• Supplier audits including appropriate control measures
• Obtaining self-declarations from suppliers
• The Code of Conduct for External Business Partners is integrated into current and future supplier agreements, which ensures there is a contractual obligation on suppliers to comply with human rights and environmental due diligence obligations in the supply chain
• When attending national procurement meetings, purchasing managers are trained in due diligence processes in the supply chain as well as in current national and European legislation
• Consistent implementation of measures to ensure that every employee is working in a safe working environment. This includes regular training to raise awareness of potential risks, and the provision of protective equipment
• Strict controls and policies are applied to minimise accidents and risks to health

Implenia promotes a culture that encourages all individuals, within and outside the company, to report possible cases of misconduct – including concerns or suspicions about human rights violations within the company. The anonymous Speak up Line (see chapter on the Compliance Management System) provides one channel for such reports.

If there are any signs of possible violations or concerns in the supply chain, the Human Rights Officer will investigate with the help of representatives from Procurement and the Legal & Compliance Department. Investigations take place digitally in accordance with a defined, transparent process, which is set out in the internal Implenia Management System (IMS). If necessary, the Human Rights Officer will consult other people from the Divisions, global functions and countries. 

Implenia sets out clear rules against child and forced labour in its “How we work” Code of Conduct, which is mandatory for all employees. The rules apply to suppliers, as well as to the company’s own business. In countries with a higher risk of human rights violations, Implenia continued to carry out unannounced inspections at plants and on construction sites in 2024.

A comprehensive regulation on this topic is contained in the policy declaration on human rights strategy adopted by Implenia. This takes legal requirements along the entire value chain into account (read more ).

According to a risk analysis carried out internally in 2024, no reasonable suspicion of child labour was found at Implenia or in its supply chain, so under Article 5(2) of the Swiss Supply Chain Act, Implenia is exempt from due diligence and reporting obligations in the field of child labour as set out in Article 964j et seq. SCO.

Construction work, especially on large sites and infrastructure projects, can lead to disturbance from noise, dust and vibrations, for example. This often necessitates greater communication about local impacts. Implenia works to reduce negative impacts on local people and to encourage dialogue – through consultation processes during planning, for example, and through regular communication with residents during the construction phase. The company also organises informative guided tours and visits for residents and school children. Wherever possible, Implenia uses the project to create positive added value for local people.

A new challenge has increasingly come to the fore in recent years: on completion of a construction project, the site has to become a living space that connects people and their diverse needs. With this in mind, Implenia, with Wincasa, has been expanding its range of services around community management for some time now. Especially in mixed-use sites, this approach ensures that life in residential buildings, offices, hotels and business areas intertwines harmoniously. 

In Switzerland, Implenia participates in the “CAS Reconstruction Ukraine”, which is trying to make a concrete and sustainable contribution to the reconstruction of Ukraine. This training programme helps people help themselves, enabling Ukrainians with a connection to the construction industry to actively shape their country’s reconstruction. Bern University of Applied Sciences BFH, working with the Swiss government and the construction industry, is responsible for this innovative initiative. 

In the Swiss canton of Vaud, Implenia is a partner of the disability insurance scheme and has recruited new employees via various reintegration programmes (read more).