Business ethics is a standard of high strategic importance for the LOTOS Group. Functioning in a transparent manner, with due care to respecting high ethical standards is our priority. The formulated corporate governance principles help us conduct our business in a responsible manner and with respect for our stakeholders. These principles are a set of ethical business behaviours and regulations that allow balancing the interests of all capital market entities involved in the operation of companies. Respecting the corporate governance principles creates value for our shareholders and enhances our credibility with them, what in result improves our competitiveness on the market.
Implementation of the corporate governance principles in LOTOS Group aims to:
- ensuring transparency of the Grupa LOTOS S.A. activities as a listed company,
- increasing the confidence in relations with the stakeholders,
- increasing openness and accessibility for investors,
- consistent building of the company’s value for the Shareholders.
If any of the Corporate Governance principles would be infringed, we are obliged to report such situation. Regardless, if the infringement is a permanent or incidental. Moreover, we publish reports on application of the Corporate Governance principles along with our annual reports.
The foundation of the ethical culture in LOTOS Group is the Ethical Programme. On the one hand, it builds value for our employees and external stakeholders and on the other hand it enables effective management of organizational culture. The key elements of the Programme are:
- Code of Ethics, effective since year 2013,
- Ethics Officer, appointed in year 2016,
- reporting channels,
The Code of Ethics determines the system of supported ethical values as well as norms and standards of conduct, which should be followed by our employees, both in work and in relationships with key groups of stakeholders of the LOTOS Group.
The enforcement of the Code of the LOTOS Group is secured by the Ethics Officer, who addresses all the notifications on the Code infringements. The stakeholders of the Group have the right to report any suspicions as well as fact that raise their concerns. The available forms of reaching the Ethics Officer are:
- direct meeting at the time suitable for the employee, prearranged via telephone,
- a call or leaving a message for the Ethics Officer (tel. +48 58 308 80 70),
- sending an email: firstname.lastname@example.org,
- filling the report form, at www.lotos.pl website,
- sending a traditional, written letter.
We also build our ethical culture by maintaining coherence with the collection of Best Practices of WSE Listed Companies. We are subject to the rules and regulations contained in this
set of corporate governance principles, believing that this translates into shaping our relationships with the market environment and is an important element of building our competitive position.
Moreover, the Group has a Misconduct Prevention Policy, which aims to improve the security of our business processes by managing the risk of potential fraud. Thanks to the anti-fraud system, we minimize the possibility of fraud, reduce their harmful effects and mobilize resources that accelerate the return of the organization to the situation preceding. Our stakeholders can report any suspicions regarding possible misconducts within the Group to the Internal Audit Office of the LOTOS Group.
In our organization there is no consent for any type of misconduct, including corruption. Since 2014, we have been one of the signatories of the global United Nations Global Compact Call to Action on Anti-Corruption initiative, which unites business in the fight against all forms of corruption. Anti-corruption policies and procedures are known not only to management board members, but also to all employees of 13 companies belonging to the Corporate Group. Each newly hired employee receives basic information about the Anti-Fraud Policy and employee responsibilities in this area as part of the training.
In 2017, we continued to raise and monitor standards of solutions aimed at limiting the possibility of fraud, including corruption. Last year, we made also evaluation of the effectiveness of our activities in this area (using a questionnaire survey, conducted once every three years), which shows that awareness of the risks of fraud in our company and the perception of action for preventing and detecting fraud as an effective, have significantly increased since the previous edition of the study. This was due to a number of our actions:
- implementation of the Fraud Risk Management Program (PZRN), including education on the subject of identifying threats, informing about responsibility for corruption actions and crimes, conducting explanatory proceedings in the case of reported suspicions of fraud and implementing mechanisms limiting threats
- implementation of the Anti-Fraud Policy in the LOTOS Group, which includes both a clear position of the Management Board regarding fraud and the process of proceedings as well as reporting channels in case of suspicion of abuse
- creating a Risk Management Card specifying how to manage and monitor risk, as well as a risk mitigation plan and how to proceed if it occurs
- using a CSR clause in offers and contracts agreements (including anti-corruption)
- creating the Fraud Risk Management Team within the Internal Audit Department
- establishing the Verification Department of Contractors of the LOTOS Group
- imposing on all companies of the Group the obligation to verify contractors in accordance with the procedure
- conducting training to prevent abuse in the subsidiaries of the Corporate Group