FIGHTING BRIBERY & CORRUPTION

FIGHTING BRIBERY & CORRUPTION

ENKA has adopted the ten principles of the United Nations Global Compact, which is designed to establish the concept of responsible business management. In running its activities, ENKA opposes all forms of bribery and corruption and will never allow real or legal entities to receive or pay bribes, directly or through third parties, even if this leads to a loss of business or delay.

In the ENKA Code of Business Conduct, ENKA states that it has adopted the principle of “Zero Tolerance for Bribery” under the section “Doing Business Globally”, as part of its determination to comply with relevant laws, regulations and principles.

Zero Tolerance for Bribery

ENKA will not tolerate bribery of any form with any third party, public or private, whether done directly or indirectly through third parties, even if we lose business or encounter delays because of our refusal to do so.

A “bribe” is an offer or promise to give, or the giving of, or authorizing to give, anything of value or another advantage to improperly influence the actions of a third party, public or private. Bribes may include money, gifts, travel or other expenses, hospitality, discounts, favours, business or employment opportunities, political or charitable contributions, or any direct or indirect benefit or consideration. Improper influence typically involves the intent to secure a quid pro quo to buy the misuse of someone’s position.

Bribes violate anti-corruption laws. It is your duty to know and follow the local and other applicable anti-corruption laws that apply to your assigned duties. Consequences for violating anti-corruption laws are severe for both our company and the individuals involved, including possible civil and criminal liability.

No ENKA employee should suffer demotion, penalty or other adverse consequences for refusing to pay bribes.

Responsible and Transparent Management

Internal audit efforts are carried out throughout ENKA within the context of fighting against bribery and corruption and early identification of risks.

Internal Audit Committee, that consists of ENKA Finance and Accounting, Cost Control, Quality Management and Human Resources specialists, has been performing internal audits at ENKA Head Office Departments, subsidiaries and projects.

Internal Audit Committee, within the scope of its annual audit schedule, conducts process control, financial statements and reports, cost control, local and international regulations and compliance, anti-bribery and anti-corruption and quality management auditing activities.

These audits are performed and reported by its more than 30 competent and experienced auditors, in compliance with International Auditing Standards and corrective actions against identified findings are implemented expeditiously.

Each ENKA employee shall behave in an open and transparent manner about their processes and activities during those audits.

In addition to internal audits that are performed in accordance with ENKA internal audit procedures, ENKA assures its responsible and transparent management via regular external audits that are conducted by independent audit firms.

Facilitating Payments

At ENKA, facilitating payments are prohibited, unless they are:

  • Pre-approved in writing by the Legal Department
  • Allowed under all applicable anti-corruption and local laws; and
  • Properly and accurately accounted for in our company’s records

Use of Agents, Consultants, Representatives, and other Third Parties

ENKA may be liable under anti-corruption and local laws not only for the actions of our employees, but also those of our business partners. If you have a reasonable suspicion that a business partner or other third party might pay a bribe, but fail to take the appropriate steps to attempt to prevent such payment, which may be seen as implicitly authorizing the bribe.
We expect our joint venture partners, suppliers, contractors, consultants, agents and other busi-ness partners to maintain a zero tolerance for bribery.

If you interact with agents or other third parties, such as joint venture partners, suppliers, subcontractors, or consultants, you must follow the proper practices put in place by ENKA, including due diligence procedures and contractual provisions. You must report immediately any suspicious or questionable behavior transactions or receipts to the Ethics Hotline contact number stated in the clause 9.2 of the Code.

For more information, please download our code of business conduct