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Trust &
Transparency
Center

2.1 Compliance, Integrity, Code of Conduct

The integrity and independence of research, as well as the responsible use of public and private funds, are the cornerstones of acib GmbH. To embed these values within its organisation, acib GmbH has implemented a comprehensive compliance system and a binding Code of Conduct. On this page, we provide information on the key principles of this framework, which is binding on all acib GmbH staff in the form of a service instruction.
For all other acib members, in particular university staff, this Code serves as a mandatory supplement to the regulations of their respective home institutions for the duration of and within the scope of their work on acib projects. In this way, we ensure ethically impeccable conduct and protect both the centre and the individual from legal and reputational risks
In doing so, we always maintain a sense of proportion: acib is an agile research centre, not a global industrial conglomerate. We act responsibly and with integrity, but reject paralysing bureaucracy that would stifle our core scientific work in favour of purely formal legal considerations. Our aim is research in the real world, not the administration of bureaucratic theory.

Legal framework and public office status

acib GmbH operates as an interdisciplinary research centre at a highly sensitive interface between science and industry. Due to its shareholder structure, acib is subject to scrutiny by the Court of Auditors as well as strict regulatory requirements.
Governance standards and legal basis: acib’s activities and corporate governance are guided by internationally recognised standards for “good governance”. These include, in particular:
  • Federal Public Corporate Governance Code (B-PCGK): As a company subject to audit by the Federal Audit Office, acib is committed to the principles of the B-PCGK. This Code sets high standards for transparency, cooperation between the management and the supervisory board, and accountability to the public.  Link to the B-PCGK
  • Federal Public Procurement Act (BVergG): As a public contracting authority or institution subject to audit by the Court of Auditors, acib undertakes to comply with the provisions of Austrian public procurement law. This guarantees transparency, competition and the equal treatment of all bidders in the procurement of services. Link to B-VergG
  • COMET Cooperation Agreement: This governs the contractual basis for cooperation with partners within the framework of the central COMET programme, in strict compliance with FFG guidelines and the EU R&D&I Framework for State Aid.
  • National law and jurisdiction: In accordance with our cooperation agreements, all agreements are generally subject to Austrian or EU law (excluding conflict-of-law rules (IPRG) and the UN Convention on Contracts for the International Sale of Goods [WKO information on differences]). The ordinary place of jurisdiction is Graz, unless expressly agreed otherwise in individual cases.
Special status under criminal law: Employees of acib GmbH and university staff working on projects are considered public officials within the meaning of Austrian criminal law on corruption (Section 74(1)(4a) of the Austrian Criminal Code). This means that the strictest legal provisions regarding bribery, acceptance of benefits and influence by third parties (“bribing”) apply. Information on criminal law relating to corruption

Core principles of integrity

To effectively prevent corruption, acib adheres to five key compliance principles:
  1. Principle of separation: There is a strict separation between gifts and business transactions.
  2. Principle of transparency: All gifts, payments and exchanges of services in the form of contracts must be disclosed.
  3. Principle of documentation: All services are documented in writing and retained for at least 10 years.
  4. Principle of equivalence: Services and consideration must be in a reasonable, market-standard relationship.
  5. Principle of contract and legality: All cash flows and exchanges are based, without exception, on clear, written agreements or authorisations.

Handling of benefits, gifts and invitations

acib safeguards its independence through clear rules governing the handling of material and non-material benefits. A strict distinction is made here between the personal level of employees and the level of the Centre as an organisation.
  • Personal prohibition on acceptance: The personal acceptance of monetary benefits (such as cash or vouchers) is prohibited without exception.
  • Benefits to the Centre: Decisions regarding the acceptance of benefits, sponsorship or donations are made exclusively by the management on the basis of written agreements.
  • Low-value gifts: The personal acceptance of promotional gifts (pens, calendars, notepads) is permitted, provided the individual value does not exceed EUR 50.00 and the items are clearly mass-produced promotional items intended to enhance the Centre’s image (“gadgets, gimmicks, giveaways”).
  • Social events and entertainment: The personal acceptance of tickets for entertainment events (e.g. concert tickets, VIP tickets) is generally not permitted.
  • Hospitality and reciprocity: Participation in working lunches is permitted provided there is a clear business reason and the hospitality is customary for the location and appropriate. We strive for balance and reciprocity in this regard.

Management of conflicts of interest

A conflict of interest arises when private interests could jeopardise the objective performance of professional duties. acib pursues a zero-tolerance policy in this regard.
  • Central procurement and the multi-eyes principle: All procurement processes are handled by the central procurement office. This ensures compliance with the Public Procurement Act (BVergG) and consistently applies the multi-eyes principle.
  • Secondary employment and dual employment: Employees are obliged to declare all gainful secondary employment in advance. acib welcomes dual employment with academic partners (universities), provided there is a strict separation of roles. Roles with corporate partners require particularly careful assessment on a case-by-case basis.
  • Conflict of interest: Close personal relationships with business partners or applicants must be disclosed. Those affected do not participate in the relevant decision-making processes.

Compliance Board (COMBO) and Oversight

To monitor compliance standards, acib has established a Compliance Board (COMBO).
  • Independence: The COMBO serves as an independent point of contact for compliance issues and is firmly integrated into the whistleblowing system.
  • Reporting channel: The COMBO reports directly to the management and, once a year, to the Audit Committee of the Supervisory Board, whilst ensuring confidentiality and the protection of identities.
  • Supervisory body: To avoid conflicts of interest at management level, an independent reporting channel exists directly to the Supervisory Board to rule out corruption at management level.

International context: FCPA and UK Bribery Act

acib is aware of the global reach of anti-corruption laws such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
  • Compatibility: As Austrian regulations for public officials are among the strictest in the world, acib’s standards generally meet or exceed the requirements of these international standards.
  • Choice of law: acib does not directly submit to foreign jurisdictions, but ensures the necessary compliance for global value chains through its internal processes.

Export control, sanctions and PEP due diligence

  • Export control (dual-use): acib is committed to strict compliance with EU export control regulations for dual-use goods.
  • Sanctions list screening: We ensure that no business relationships are maintained with persons or organisations listed on international sanctions lists (EU, UN).
  • Politically Exposed Persons (PEPs): Cooperation with PEPs or persons closely associated with them is subject to enhanced due diligence.
  • Russia/Belarus embargo: Due to the EU sanctions regulations in force since 2022 (in particular Regulation (EU) No 833/2014, as amended), cooperation with Russian and Belarusian partners is subject to specific restrictions. This applies in particular to the transfer of dual-use goods and technologies, cooperation with sanctioned entities and individuals, and payment transactions. acib does not seek to engage in cooperation in these countries.

Fair competition and competition law

Fair competition and competition law As a link between numerous industrial partners – who are often in direct competition with one another – acib strictly ensures compliance with competition law. As we routinely work on multi-company projects, we see ourselves as an impartial mediator of differing interests, with transparency being our guiding principle.

Pre-competitive platform & innovation collaborations

acib acts as a neutral platform for the joint development of technological foundations (Joint R&D). This form of collaboration, even between competing companies, is permissible and encouraged under antitrust law in accordance with Section 1 of the Austrian Antitrust Act (KartG) and Article 101 of the TFEU. It primarily serves to promote innovation and increase efficiency in research. Such collaborations are exempt from the prohibition on cartels under the conditions of the European Research and Development Block Exemption Regulation (R&D BER), as they deal with pre-competitive matters (pre-competitive research) and exclude any unlawful market sharing or price fixing.

Ensuring information barriers

acib implements targeted organisational and technical measures to prevent the unauthorised exchange of competition-relevant information (e.g. prices, strategies, market shares) between competing partners:
  • IT access rights policy: Data and documents relating to individual projects are protected by a restrictive role and rights management system. Employees only have access to the information necessary for their specific project (“need-to-know principle”).
  • Confidentiality agreements (NDAs/CDAs): All employees and participating researchers are obliged to maintain strict confidentiality towards third parties and other project teams.
  • Physical and logical separation: Where necessary, project teams are separated in terms of personnel or isolated by clear communication protocols to act as a “security filter” between the interests of the partners. acib sees itself here as a neutral intermediary that consolidates progress without compromising trade secrets.

Transparent procurement processes

Contracts with external parties are awarded exclusively on the basis of objective criteria and in compliance with fair competition conditions. The Federal Procurement Act serves as an objective benchmark for fair competition.

Avoiding breaches of antitrust law:

Agreements with partners regarding market sharing or pricing are strictly prohibited. acib projects are not instruments for market foreclosure, but open innovation vehicles

Handling of insider information

Through close cooperation with listed companies (e.g. pharmaceutical and chemical groups), acib members often gain access to confidential information that could influence the share price (insider information).
  • Strict ban on insider trading: The use of insider information for private share trading or the disclosure of such information to third parties (“tipping off”) is strictly prohibited and will be prosecuted. acib members are aware that a breach of these provisions not only has consequences under employment law but may also result in severe criminal sanctions under the Market Abuse Regulation and the Stock Exchange Act.
  • Confidentiality: All project-related data is treated with the utmost confidentiality so as not to jeopardise the market integrity of our partners. This applies in particular to research results that are potentially price-sensitive before they are officially published or patented.

Bioethics and scientific responsibility

Guided by the highest standards of the global pharmaceutical industry, acib is committed to ethically responsible research.
  • Responsible Research: We reflect on the societal impacts of our biotechnological innovations and act in accordance with internationally recognised ethical guidelines. We are committed to proactively assessing the impacts of our research on people and the environment and addressing ethical concerns at an early stage (see also acib.at/scientificintegrity).
  • Animal welfare and GMO safety: Where biological resources or genetically modified organisms (GMOs) are used, we ensure strict compliance with all safety and ethical standards that go beyond mere legal compliance. We are committed to reducing animal testing and apply state-of-the-art safety concepts for biotechnological processes. Further details and our specific guidelines can be found at acib.at/ethics.

Research Security & Foreign Interference

In an increasingly complex geopolitical environment, acib protects its research results and the intellectual property rights of its partners from unlawful external influence.
  • Protection against knowledge leakage: We raise our staff’s awareness of risks posed by espionage and unlawful technology transfer. acib implements processes to identify critical technologies and ensures that valuable IP does not leak out unchecked. Collaborations with partners from high-risk third countries are subject to a separate, risk-based security assessment.
  • Supply chain integrity: We ensure that critical infrastructure and laboratory equipment are sourced from trusted suppliers to guarantee the security and sovereignty of our research environment and to rule out manipulation or espionage via compromised hardware.

Digital sovereignty & IT resilience

acib is aware of the strategic dependencies within a globalised digital infrastructure. We address these challenges through a balanced hybrid approach that combines technical necessities with local security:
  • Global cooperation via multinational corporations: To ensure efficient collaboration with our international partners in science and industry, acib utilises market-leading cloud solutions (in particular Microsoft). This choice is a conscious decision in favour of global compatibility and the highest security standards. We are aware of the associated sovereignty issues, but assume that multinational corporations of this scale fulfil their responsibilities regarding data security and compliance in accordance with the highest global standards.
  • Prioritisation of European data centres: Within this global infrastructure, acib specifically prioritises European data centres (data residency). In doing so, we ensure that the storage and processing of sensitive data takes place primarily within the European legal jurisdiction, whilst specifically favouring locations with high local availability (Austria/Vienna region).
  • Regional resilience & backup strategy: To ensure reliability and data sovereignty, acib also relies on strong regional IT partnerships (e.g. with ACP). We safeguard our critical research data through a dedicated backup solution that is independent of the primary system. This strategy ensures that we remain operational even in the event of widespread disruptions to global services and retain control over our most important digital assets.

Integrity in Collaboration with Partners

acib expects its business partners, industry partners and external institutions to share the Centre’s high ethical standards and to strictly comply with applicable legal provisions.
  • Know Your Partner (KYP) & Due Diligence: We take the identification of our partners seriously. Before entering into a business relationship, we carry out appropriate checks (e.g. via Firmenkompass, compliance checks, as well as our own surveys and research). We are committed to a rigorous “Know Your Customer” approach to ensure the integrity of our supply chain.
  • Priority of research: Diligence with a sense of proportion rather than paralysing bureaucracy: acib operates in the real world of scientific practice, not in a vacuum of purely legal theory. As a research-focused centre, we reject ‘over-compliance’ where it merely incurs administrative costs without offering any substantive added value. If we were to translate every political U-turn or every theoretical regulatory eventuality into bureaucratic hurdles without a sense of proportion, cutting-edge research would no longer be possible at our site. Our resources are channelled primarily into science, not into the administration of excessive formal processes.
  • Pragmatic assessment approach: In the interests of proportionality, acib refrains from requiring standardised, extensive self-declarations from every partner. Instead, we rely on professional database queries, internal research and mutual obligations within the framework of our contracts.
  • Risk-based evaluation: In-depth checks are only carried out on an ad hoc basis or where this is mandatory under legal provisions or specific funding guidelines.
  • Shared values: We prefer to work with partners who have a proven commitment to fair competition, anti-corruption and high social and environmental standards. This includes full respect for human rights.
  • No improper influence: Contracts and collaborations are awarded exclusively on the basis of quality, innovation and cost-effectiveness. Attempts to exert undue influence will result in the immediate termination of the business relationship.

Consequences of breaches

Breaches of compliance requirements constitute a serious breach of professional duties and will be punished by all means available under labour, civil and criminal law.
In case of doubt: Contact COMBO at compliance@acib.at or the Legal Department at legal@acib.at or use our Integrity Link.