The Anti-corruption Program of the SKUPINA company
1. Against corruption
For the purposes of this Anti-corruption Programme the corruption is defined as the behavior of the abusive position or function for personal gain in a manner that is contrary to the law and ethical rules.
The SKUPINA company has decided to accede to the Anti-Corruption program, the purpose of which is:
a) minimize corruption risks in the business activities of the SKUPINA company,
b) pre-emptively act against the corruption risks within the company in providing products and services for the company,
c) as an important Czech business company to give an example of how to proceed in the prevention of corruption and unethical conduct
The Anti-Corruption program of the SKUPINA company consists of:
· the code of ethics of employees of the SKUPINA company, which special section is devoted to the field of public procurement
· the ethics of e-mail, to which anyone can report a complaint on corruption or unethical conduct in connection with the SKUPINA company
· the set of processes and measures to evaluate corruption risks, according to the company’s activities, groups of employees, or differences in markets in which the SKUPINA company operates.
The Anti-corruption Program of the SKUPINA company is available not only to employees of individual companies, but it is accessible and usable by the general public, including contractors, dealers, customers, media and representatives of the public administration in the Czech Republic and on all other world markets, where SKUPINA company develops its activity
2. The SKUPINA company Code of Ethics
One of the basic tools of the SKUPINA Anti-Corruption program is the Code of Conduct for company employees who are obligated to comply with it.
However, some of its provisions also affect SKUPINA partners, such as the company’s sales offices. The Code of Conduct includes:
· Prohibition of corruption,
· prohibition of conflict of interest negotiations,
· reporting a complaint of corrupt or unethical behavior,
· special obligations in the field of trade in the implementation of the anti-corruption program,
· principles of sponsoring or for donations to political parties and movements,
· commitment to spread the corruption program beyond SKUPINA.
3. SKUPINA sponsorship rules
The SKUPINA sponsorship rule is that it must not be tied to the realization of any business opportunity, whether in the public or private sector. Similarly, there must be no sponsorship that would in practice fulfill the definition of conflicts of interest, ie. eg sponsoring projects by SKUPINA employees and their family members. As a rule, sponsorship activities are published by SKUPINA in the form of a press release and information on its website.
Support of political parties and movements
SKUPINA’s support for political parties and movements must be transparent. At the same time, this support must never be tied to any business opportunity in the public sector. SKUPINA strictly complies with all legal obligations regarding possible support for political parties.
4. Gifts and presents
It is forbidden to provide partners with unreasonably luxurious accommodation, unethical and expensive entertainment services, or to give them gifts the value of which is manifestly inadequate. This behavior is considered potential corruption in relation to SKUPINA partners. Likewise, SKUPINA managers and employees are prohibited from accepting such manifestly inappropriate services or luxury gifts. In the event of such a partner’s behavior, SKUPINA employee is obliged to report this fact to his superior.
5. Facilitation payments
In some foreign markets, public sector officials may be required to pay “facilitation payments” that are lawful under local law. It is strictly forbidden for SKUPINA to pay fees. Business commissions for private sector partners are not included in the definition of settlement fees, for example, through dealerships, licensing agreements, or agency agreements.
6. Participation of SKUPINA in Offset Programs
Although Czech legislation in accordance with European Union law no longer allows the involvement of Czech companies in offset programs in the case of public contracts of the Czech government and ministries, offsetting programs may also be part of the conditions of foreign contracts. A typical requirement, even in the case of advanced democratic states, may be a requirement for a partial transfer of production, which can be considered a direct offset. SKUPINA, in cooperation with foreign partners, always implements offset programs in accordance with national legislation, in order to meet the customer’s requirements for acquiring the ability to partially manufacture and service the products. SKUPINA refuses and does not participate in offset programs that only involve the procurement of non-business related engagements that involve corruption risk and could be misused as a corruption channel. As a general rule, SKUPINA informs about activities that can be included in the direct offsets category as part of the publicity around the contract (only the major and publicly controllable projects are eligible for the transfer of production).
7. SKUPINA Ethics Line
In order to create a unified information channel for imparting behavior that is unethical, corrupt, illegal, violating work safety or environmental protection, SKUPINA has set up an ethical e-mail to which anyone can initiate the above action in the form of:
Sending a request to: firstname.lastname@example.org
SKUPINA has a clear preference for not being anonymous, because anonymous suggestions are in themselves a risk of unethical behavior and abuse of the ethical line. But no one is prevented from submitting the complaint anonymously.
The beneficiary of the complaint is the management of SKUPINA, which confirms to the sender its receipt and informs him within 14 days how the complaint has been handled, or at what stage of the investigation. Upon examination of the complaint, it informs the sender of the outcome of the investigation.
SKUPINA declares that it has reasonable incentives for ethical e-mail and supports it. This, of course, does not apply to false or impulsive impulses with the aim of unfairly accusing another person or society. Such a stimulus in itself is a violation of the SKUPINA Code of Conduct and Anti-Corruption Program, with all the implications arising from it.
All reports submitted are treated as confidential in order to protect the person who submitted the report and to allow for objective investigation.