* Indicators marked with „*” was subject of a assurance engagement by an independent auditor.
[102-16], [103-1], [103-2], [103-3], [406-1]
Within the Budimex Group, the Code of Ethics has been in place in all the companies covered by the report since 2010. The Code of Ethics is to set out rules aiming at preventing all forms of unethical conduct, including corruption and bribery as well as all forms of discrimination. The Code of Ethics applies to all of the Group personnel and external suppliers.
The rules of Budimex’s Code of Ethics:
It is the responsibility of the Ethics Committee to ensure the provisions of the Code of Ethics are abided by and to monitor compliance of the standards of professional ethics with the rules of the Code of Ethics. Ethics Committee was formed by the President of the Management Board and is composed of:
Every year a report on the Ethics Committee’s workings is compiled which is then handed over to the Management Board and the Supervisory Board Audit Committee.
The Ethics Committee supports implementing, managing, and monitoring the Compliance Policy, which was introduced in September 2017 (becoming effective since the date when published on the intranet website, i.e. 31 October 2017) and applies within the entire Budimex Group. The Compliance Policy means “ensuring compliance of the organisation’s activities with the applicable law, standards and internal regulations, aimed at: preventing breaches of the organisation’s good name and reputation, minimising the risks of financial losses related to the organisation’s activities contrary to the law or the internal regulations, as well as reducing the risk of exposing the organisation to civil, administrative or criminal liability”. It also states that respect for the law and ethics in business is one of the Budimex Group’s crucial rules. The following are the cardinal rules of the Compliance Policy:
At the same time, the Policy introduces the so-called Compliance System, aiming at adopting and enforcing internal regulations properly. The proper application of and compliance with the Compliance Policy is supervised by the Chief Compliance Officer appointed by the Company Management Board, and the Deputy Chief Compliance Officer, and also by the Compliance Committee established at the request of the Chief Compliance Officer, which will be composed of the representatives of each of the Company organisational departments. The Committee Chief Officer is Member of the Management Board, Head of the Legal and Organisational Department.
Failure to abide by the Code of Ethics and the Compliance Policy involves first of all legal and reputational risks. Where non-compliances are identified, there are also possible financial losses and conflicts of interests.
Also, a very important issue of diversity management is related to running business activity according to the rules of ethics. Diversity and openness are the values according to which business decisions need to be made and according to which the employment policy is implemented within the Group. Intolerance and discrimination are the risks which threaten the Group’s integrity, therefore Budimex S.A. has implemented the Diversity Policy consisting in equal treatment on the grounds of e.g. sex, age, disability, health, race, nationality.
Under the Diversity Policy, Budimex has undertaken to create an organisational atmosphere and culture ensuring respect for any diversity. The Diversity Policy deals also with recruitment, access to training courses and promotions, remuneration, combining professional duties with private life, protection against mobbing and an ungrounded dismissal. In 2017, there were no confirmed cases of discrimination. In order to manage the policy efficiently, the so-called anti-discrimination and anti-mobbing monitoring, and also a system of educational tools, training courses and workshops have been implemented. The results of carrying out this Policy are reported to the Management Board every year.
Since November 2016, Budimex has been one of the signatories to the Diversity Charter. It is an international initiative, operating for a couple of years. By joining this circle, we have undertaken to treat all our employees equally and to prevent any discrimination at work on the grounds of sex, age, nationality, disability, sexual orientation and faith. Also clients, business partners, shareholders, suppliers and subcontractors are informed of the diversity management model.
 Also the Budimex Operating Regulations guarantee respect for human rights and prevents discrimination in employment.
[103-1], [103-2], [103-3]
Each employee may either personally or anonymously notify any noticed breach of the Code or the Compliance Policy to the Ethics Committee Members or to the Chief Compliance Officer, their Deputy or to the Compliance Committee Members in writing to the following address: 40 Stawki Street, 01-040 Warszawa or by e-mail to the following e-mail address firstname.lastname@example.org or email@example.com. Only authorised Members of the Ethics Committee or of the Compliance Committee have access to the box. Also, a Compliance emergency number has been in place +48 789 404 104. Sometimes, there are also notifications being received outside this system, then they are handed over directly to suitable persons.
All the notifications are investigated with the confidentiality standards preserved, and may be the basis for working out streamlining and remedial action. Each case of breach is recorded in writing with recommendations and guidelines for further actions to be taken by a given organisational unit. The Chief Compliance Officer analyses each notification in cooperation with the Compliance Committee and/or the Office of Internal Control Committee if requested so, and assures of no work-related consequences connected with the fact of reporting notification. They are also obliged to provide the Management Board and the Supervisory Board notification with reports containing information about what actions have been taken in order to account for given notification (not more rarely than for a period of three months). Furthermore, the Supervisory Board Audit Committee may request such a report for a given period. In 2017, 5 notifications of failure to adhere to the provisions of the Code of Ethics and/or the Compliance Policy within the Budimex Group were received of which three turned out to be confirmed, however, none of these events resulted in financial losses within the Budimex Group.
The list of notifications of breaches of the Code of Ethics / Compliance Policy in 2017:
All the information about the Code of Ethics and Compliance Policy are available on Budinet − the Group’s intranet. Each new employee of the Budimex Group familiarises themselves with the Code of Ethics. Since 2016, ethics has been an element of cyclical training courses for the employees, and full cyclical training courses are planned to this end in the future.