Any information on the “Code of Ethics” and “Compliance Policy” is available on the Budimex Group’s intranet. Since 2017, the compliance matters and ethics contained in them are part of regular training activities for employees.

All employees of the Budimex Group have access to the information and tools enabling them to report the observed violations and irregularities. They include:

compliance emergency telephone (+48 789 404 104),
email addresses: and,
an electronic platform for anonymous reporting,
option of reporting in person to the Chief Compliance Officer or its Deputy.

There are also reports e.g. in the form of letters sent directly to the President of the Management Board or members of the Management Board of Budimex S.A. – Parent Entity in the Budimex Group. In such a case, they are transferred directly to people responsible for their consideration.

If the notifier so wishes, he or she shall remain anonymous and be assured that there are no business consequences associated with the notification. The Chief Compliance Officer, in cooperation with the Compliance Committee and/or the Office of Internal Control, analyses every report in detail, while respecting confidentiality standards. Every breach is recorded in writing together with recommendations or guidelines for further actions to be taken by the organisational unit relevant to the report. The Chief Compliance Officer is obliged to regularly provide the Management Board and the Supervisory Board with reports containing information on the actions that have been taken in order to explain the given report (at least for a period of three months). Furthermore, the Supervisory Board's Audit Committee may request a report for a given period at any time.

The list of reports of breaches of the Code of Ethics / Compliance Policy in 2020:

  • the probability of improper behaviour by the contract director towards subcontractors, i.e. preferring particular companies,
  • the probability of irregularities in hiring foreign employees by one of subcontractors,
  • the probability of improper behaviour by a supervisor towards an employee,
  • information on improper behaviour of an employee towards a former spouse,
  • probability of intrusion into the Budimex IT system,
  • an employee of an external company detained by the Police (family issues),
  • employee drawing attention to the use of words that may be offensive by certain people.

With respect to any irregularities in the behaviour of the contract manager and subcontractor's employees, the reported violations were not confirmed. None of those events resulted in financial losses in the Budimex Group. In other cases, employees were cautioned about correct behaviours, even in non-work relations.

2019 2020
number of confirmed corruption incidents 0 0
percentage of employees familiar with anti-corruption policies and procedures 1 1
percentage of suppliers familiar with anti-corruption policies and regulations (contractual provisions) 1 1