In implementing the OECD Guidelines for Multinational Enterprises, the Budimex Group adopted an Anti-Corruption Policy containing:
- a commitment to countering the phenomenon of corruption,
- regulation of internal control in the area of anti-corruption – including the establishment of a system for reporting violations,
- a commitment to anti-corruption training aimed at preventing and detecting potential corruption incidents, rules for dealing with violations and removing their consequences.
The Anti-Corruption Policy equips the employees of the Budimex Group with clearly defined rules of conduct aimed at avoiding corruption incidents. The centrepiece of the activities conducted by the Budimex Group in this area is the adopted principle of zero tolerance for corruption.
In connection with the risk analyses conducted in the Budimex Group, the following areas potentially exposed to the occurrence of corruptive phenomena have been identified:
- obtaining and concluding subcontracts,
- relations with Investors,
- relations with construction authorities.
The identification of corruption risks is performed as part of the ongoing risk identification process described in the subsection on identifying risks as part of due diligence processes.In the year for which this non-financial report is submitted (started 1 January 2022, ended 31 December 2022), no incidents of corruption were reported via Compliance’s internal communication channels.
Significant events between the end of the reporting period and the date of publication of this Report
In accordance with the information published in Current Report No. 6/2023 on 2 February 2023. The Management Board of Budimex SA informed that – according to the information obtained from FBSerwis SA – the President of the Management Board of FBSerwis SA has been charged in the proceedings conducted by the Regional Prosecutor’s Office in Katowice. At the current stage of these proceedings, according to the information obtained, the above-mentioned person remains in custody, the process is underway and there is no decision on possible temporary arrest. The abovementioned Member of the Management Board of FBSerwis SA performs at the same time the function of a Member of the Management Board of Budimex SA. Information provided to Budimex indicates that the case in connection with which the proceedings are pending is not related to and does not concern the operating activity of Budimex SA.
In accordance with the information published in Current Report No. 8/2023 on 3 February 2023. The Management Board of Budimex SA, with reference to Report No. 6/2023 of 02 February 2023, informed that – according to the information obtained from FBSerwis SA – a decision on the application of a preventive measure in the form of temporary arrest for a period of 2 months was issued with regard to the President of the Management Board of FBSerwis SA.
In accordance with the information published in Current Report No. 9/2023 on 6 February 2023. The Management Board of Budimex SA, with reference to Report No. 06/2023 of 02 February 2023 and No. 08/2023 of 03 February 2023, informed that the Management Board of FBSerwis SA decided to suspend the President of the Management Board of FBSerwis SA for a period of 2 months. The same decision was taken by the Supervisory Board of Budimex SA.
In accordance with the information published in Current Report No. 15/2023 on 20 March 2023. The Management Board of Budimex SA informed that, according to the information obtained, the preventive measure mentioned in Current Report No. 8/2023 dated February 3, 2023 against the President of the Management Board of FBSerwis SA has been repealed.
The topic of corruption is discussed during ‘Welcome to the Group’ training sessions organised for newly hired employees. During the training, issues related to corruption and internal regulations aimed at counteracting it and implementing the ‘zero tolerance’ principle adopted in the Company are discussed.
In November 2022, a training course was organised for Management Board Members entitled ‘Selected Elements of Security Management at Budimex SA’, which covered such issues as:
- employee abuse in the investment process
- unfair competition in the construction industry
- giving and accepting gifts as well as sponsoring issues
- good anti-corruption practices, especially during the procurement process
- risk of liability of a collective entity
This training kicked off a series of classes that are to continue in 2023 for individual employee groups.