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Anti-corruption and anti-bribery

Both ENERGOTEST sp. z o.o. and ELEKTROBUDOWA SA are committed to prevention of unethical behaviour, counteracting any employee engagement in corruptive practices, active (offering an advantage) and passive (receiving and advantage). Potential problems related to corruption and bribery are identified as serious source of risk of loss of reputation for companies and a risk of hindrance to conducting business activity. The Companies strictly require that their employees comply with the prohibition of receiving of unjustified advantage from the co-workers, purchasers of products and services, suppliers, customers, competitors and other business partners, and with the prohibition of offering such advantage to their business partners. Expectations of both companies in this respect are described in the documents which all employees are required to follow: the Code of Ethics of ENERGOTEST sp. z o.o. and the Code of Ethical Conduct of ELEKTROBUDOWA SA100, the second version of which was approved and adopted in the end of May 2017. The system of regulation of ethical and lawful behaviour, apart from the Codes, is comprised of many regulations which indicate specific areas and expected patterns of behaviour, and also, applicable in ELEKTROBUDOWA SA and in ENERGOTEST sp. z o.o., procedure for identification and management of risk of irregularities and abuse and counteracting corruption.

The procedure applies to all incidents of irregularities and abuse and corrupt events and also to situations where there is a suspicion of their occurrence, and must be followed by every employee of the companies and persons acting on their behalf, irrespective of place of work, years of service or duties performed. It establishes uniform rules of handling the above cases and establishes the scope of examination of their reasons and identification of persons responsible for handling such cases and the scope of responsibilities for its areas. Six areas of the conducted business activity where the risk of irregularities and abuse is the most probable have been identified, and a typology of undesired behaviour in each area have been specified. The following activities are deemed particularly sensitive: the process of selection of suppliers and subcontractors, purchase of goods and services, renting facilities or equipment, project, contract, order, contract, purchase order performance, employing and establishing remuneration, maintaining financial books and registers101. Employees of both companies have an obligation to identify the risk of irregularities and abuse and corrupt acts in the scope of their tasks. The managing staff are additionally obliged to be alert to any potential possibilities of occurrence and real manifestation of irregularities, abuse or corrupt acts, related to the processes for which they are responsible.

In the event of suspected irregularity and/or fraud or corrupt acts committed by managers, employees, business partners or other business-related entities, every employee and also other individuals having relevant information are required to immediately report their suspicion to do Chief Specialist for Economic Audit / Fraud Risk Manager who implements investigation proceeding covering the mentioned above areas of the highest level of risk of irregularity and/or fraud. The outcome of such investigation, together with recommended action, is reported directly to the Management Board. The implemented procedure and inspections have the purpose of eliminating any unethical behaviour, they also provide for the possibility of corrective actions, for example actions recommended in the follow up reports. ELEKTROBUDOWA SA is also voluntarily subjecting itself to audits performed by external, independent bodies, in order to identify any irregularities and to help facilitate procedures and practices in place.
Codes of Ethics of both companies are available on their websites, while the procedure is available inside the company as a component of the system documentation. Additionally, employees of ELEKTROBUDOWA SA have acquainted themselves with the anti-corruption and anti-bribery policy disclosed in the internally circulated Newsletter, and also during in-company training102 provided by the Fraud Risk Manager.

Since 2017 ELEKTROBUDOWA SA has also had the Regulations for preventing conflicts of interest and for entering into related party transactions in place. The Regulations follow the provisions of Chapter V of Best Practice of GPW Listed Companies 2016 and specify the criteria of and circumstances in which a conflict of interests may take place in the Company and set out the rules to follow in the situation of a conflict of interests or possibility of its occurrence; the document also regulates the issues related to entering into transactions with related parties in the situation of a conflict of interests. The Regulations have been implemented with the purpose of preventing conflicts of interests in the Company, and in the situation of a conflict – its effective management and monitoring, and also to ensure that the interest of the Company is protected against its adverse impact.
In 2017 in ELEKTROBUDOWA SA and in ENERGOTEST sp. z o. o. there were no confirmed incident fulfilling the criteria of corruption103. No disciplinary penalties were imposed on employees in connection with relevant irregularities. No information was received of such incidents to occur in ELEKTROBUDOWA UKRAINE Ltd.
In respect of confirmed in ELEKTROBUDOWA SA internal incidents classified as irregularities (understood as a violation of generally binding laws or regulations, norms and standards applicable in the Company, resulting from acts or omissions, which caused or might have caused damage) it has been found out that they were caused by human errors and negligence. The Company’s response included relevant corrective and remedial actions which consisted in removal the involved employees from performing their tasks and thorough verification of areas where the irregularities had occurred, such as tender procedure and change of service suppliers, tightening operating procedures, talks with the employees.
So far ELEKTROBUDOWA SA and ENERGOTEST sp. z o.o. have not analysed their supply chains with regard to evaluation of the increased risk of corruption incidents, and the solutions adopted by them in the sphere of ethics and prevention of corruption and bribery do not impose special obligations on their suppliers and subcontractors. Aware of materiality of this aspect, ELEKTROBUDOWA SA is going to start work towards establishing a Suppliers’ Code which will regulate the issues of cooperation with suppliers and subcontractors, complementing the purchasing and offering procedures already in place, and which will ensure that the relations with suppliers are managed in the way most transparent as possible, with respect to law and internal regulations, and which will define the expected scope of responsibility of suppliers and subcontractors in respect of preventing corruption and bribery.

103S 10.2.; S.10.3.; G4-SO5

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