Bribery and Corruption Risk Assessment
Emphasis on Combatting Bribery and Corruption
The Group has a clear policy on combatting bribery and corruption. Under ENRC’s ‘Overarching Principle’, employees should act with integrity and honesty and to the highest ethical standards.
The Code of Conduct is explicit that ENRC is resolutely opposed to bribery and corruption in whatever form it may take and all Employees are required to ensure ENRC’s opposition is made clear in all circumstances.
Regarding gifts and hospitality, employees, their family members and their friends must not offer or accept excessive or inappropriate gifts or hospitality related to ENRC’s business. In terms of legal and regulatory compliance, employees must comply with all laws and regulations that apply to carrying out their duties and that apply to ENRC generally. These laws would include the Bribery Act and any other bribery/corruption legislation which may apply.
The Code of Conduct applies to every employee within the ENRC Group and to associated persons who, whilst not necessarily being employees of the ENRC Group, are conducting business on behalf of ENRC.
The requirements and obligations contained in the Code of Conduct, including those relating to bribery and corruption, are personal to each employee. Breaches of the Code of Conduct are a disciplinary matter and any breaches are dealt with in accordance with local internal procedures relating to a disciplinary process.
Bribery and Corruption Risk Assessment
Group risk assessments are conducted on a regular basis and discussed at Audit Committee meetings as part of each compliance report.
From August 2010, the Group Head of Compliance has been assessing and formally reporting on compliance risks throughout ENRC, as well as to the General Counsel on an ad-hoc basis.
In July 2011, Deloitte commenced a formal and comprehensive risk assessment of the Group. The assessment is ongoing and will be used to inform any necessary changes to ENRC’s policies and procedures.
Whistleblowing
ENRC strives to achieve the highest standards of corporate governance. There is a clear emphasis on combatting bribery and corruption. Under ENRC’s ‘Overarching Principle’, employees should act with integrity and honesty and to the highest ethical standards. The Code of Conduct is explicit that ENRC is resolutely opposed to bribery and corruption in whatever form it may take, and all employees are required to ensure ENRC’s opposition is made clear in all circumstances.
There is a robust framework in place by which ENRC employees can raise any concerns they may have about the workplace fraud or mismanagement on a confidential basis. All internal reports received from the Whistleblowing Hotline undergo an initial assessment by the Compliance Department in London. Serious claims are sent directly to ENRC’s General Counsel, with the oversight of the Audit Committee.
In 2011, the whistleblowing procedure was upgraded with the introduction of an externally managed whistleblowing helpline, available in the four main languages of the jurisdictions in which ENRC operates. The hotline is fully staffed by an independent outside contractor 24 hours a day 365 days a year. If requested, anonymity is respected for those making such reports.