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 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 does 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 each employee’s duty to know and follow the local and other applicable anti-corruption laws that apply to their 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.

We demand from all our business partners, suppliers, contractors, consultants and other 3rd parties to comply with our zero tolerance for bribery policy.

Responsible and Transparent Management

ENKA considers audits and assessments as a core element of continual improvement and risk identification. 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, Sustainability 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 this context ENKA internal audit teams conduct audits to assess the compliance against ISO 9001, ISO 27001, ISO 14001, ISO 45001 standards, Corporate Quality, HSE (Health, Safety, and Environment), Sustainability, Finance and Accounting, Human Resources requirements and procedures, ENKA Code of Business Conduct, local and international laws and regulations and contract requirements. In 2019, all ENKA projects and 78% of ENKA subsidiaries were audited by internal audit teams. In addition to the regular audits, Ethics and Compliance audits were put into practice to assess the ENKA projects and subsidiaries against human rights, worker rights and anti-corruption and anti-bribery practices. Within the context of Ethics and Compliance audits a part of ENKA’s projects and subsidiaries operating in Turkey, Russia, Kazakhstan, Georgia and Iraq were assessed against human rights, worker rights and anti-corruption and anti-bribery practices.

We also use Supplier Sustainability Audit Program as a tool to manage the supply chain risks and ensure that our suppliers and subcontractors complies with ENKA’s and international standards. We started performing supplier sustainability audits to assess their compliance on environmental, social and ethical management, human rights and labor, occupational health and safety and anti-bribery and anti-corruption policies. Corrective actions are planned for identified nonconformities and improvement areas and their implementations are monitored regularly. We aim to widen our area of assessment with more suppliers and subcontractors with the contributions of our subsidiaries each year.

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.