Why is this important?
Ethical behavior is paramount for establishing a good reputation, building and maintaining the trust of our business partners, customers and stakeholders.
Our core policies and commitments include OMV Petrom Code of Conduct, Code of Business Ethics and Whistleblowing Platform Directive. In 2021, the Whistleblowing Platform Directive has been updated to address all areas relevant for OMV Petrom activity, in accordance to provisions of EU Directive 1937/2019 on the protection of persons who report breaches of Union law (the Whistleblowing Directive). We also have a fully implemented Compliance Management System. We are committed to raising business ethics awareness for targeted OMV Petrom employees through trainings and compliance programs.
We monitor the training level as well as conflicts of interest of those who work for us.
OMV Petrom has a fully implemented compliance management system that includes internal rules, processes and controls aiming to prevent, monitor and detect potential business ethics deviations and promote a business ethics culture within the organization. The compliance management system gravitates around the Code of Conduct and the Code of Business Ethics. Both the Code of Conduct and the Code of Business Ethics are signed by OMV Petrom Executive Board and apply in all countries where the company operates. The Zero tolerance policy towards bribery, fraud, theft and other forms of corruption is clearly stipulated in the Code of Business Ethics that is endorsed by the Executive Board. The Code of Business Ethics is communicated to all OMV Petrom employees via all the communication channels available in the organization.
The Code of Business ethics is mandatory for everybody who works for OMV Petrom, including OMV Petrom’s subsidiaries in Romania, Bulgaria, Moldova and Serbia, including our employees and all external staff that works for us under secondment agreements.
The internal Whistleblowing Directive lays out how employees and externals can confidentially and anonymously make a whistleblower report regarding all relevant topics pursuing the EU Whistleblowing Directive, including (but not only) corruption and bribes, conflicts of interest, competition law, and capital markets law.
The OMV Petrom Compliance Management System was audited in terms of design, implementation, appropriateness and effectiveness according to international Standard IDW PS 980 in 2013 and 2017. The Compliance Management System is regularly reevaluated under IDW PS 980.
The risks are reassessed on a semi-annual basis, a requirement under EWRM.
It is of strategic importance for us to make sure that every single employee is fully aware of our ethical values and principles. There are two main trainings conducted, namely on business ethics and antitrust law topics.
The compliance team receives training, participates in meetings and workshops, which also include sharing of country specific experience on implementation of whistleblower programs. Raising business ethics awareness for all OMV Petrom employees is achieved through trainings and the compliance communication program.
Our planned actions include periodical mandatory trainings on business ethics for white-collar employees, Competition Law mandatory for all employees in the most risk-exposed areas, direct business ethics trainings (virtual or face-to-face) for managers, and Competition Law trainings (virtual or face-to-face) for managers and employees in the most risk-exposed areas.
In 2021, we worked specifically on:
- enhancing the training and awareness activities in OMV Petrom and the subsidiaries outside Romania with a focus on whistleblowing
- starting the development of a new compliance tool accessible for OMV Petrom employees from their mobile phones
- enhancing third party risk mitigation by closer scrutiny of first tier subcontractors
The Integrity Platform was expanded in view of new legal requirement and can be used to make reports of perceived violations in the following legal areas:
- Corruption and bribery
- Conflicts of interest
- Cartels/unfair competition
- Capital market law
- Public procurement
- Environmental protection
- Product/food safety and consumer protection
- Corporate tax regulations
- Data protection
Maintaining a direct and permanent dialogue with the employees of OMV Petrom subsidiaries is an important objective of the awareness and training activity for the Compliance team. In this regard, meetings were held, both face to face and online with the management and employees of the three OMV Petrom subsidiaries, Moldova, Serbia and Bulgaria. The scope of these meetings was to deliver compliance refresher sessions on Business Ethics, Competition Law and other compliance aspects.
In addition, a Compliance workshop was organized on whistleblowing aspects, involving Local Compliance Officers from OMV Petrom subsidiaries in Romania, Moldova, Bulgaria and Serbia.
- E-learning trainings on Business ethics: 4,100 participants
- E-learning trainings on Competition Law: 212 participants
- Virtual face-to-face trainings on Business ethics: 252 participants
- Virtual face-to-face trainings on Competition law: 84 participants
Spot checks: quarterly spot checks on the topics of conflict of interests and gifts & invitations.
Whistleblowing: zero relevant whistleblower reports on the topics of the Code of business ethics.
Incidents of corruption: zero incidents resulting in contracts with business partners or employees terminated or not renewed due to corruption.
Public legal cases: zero public cases involving corruption brought against the organization or its employees during the reporting period. However, there are two legal actions pending with regard to competition law matters in subsidiaries in Moldova and Bulgaria. Our performance is detailed in the Performance in Detail section of this report.
Our progress is reflected in our actions to raise increase business ethics awareness for all OMV Petrom employees through trainings and compliance communication program.
The new compliance tool was developed, the Compliance App will be available in 2022 on mobile phones of OMV Petrom employees and will provide a user-friendly modern communication channel to facilitate contact with the Compliance team and send compliance reports or access compliance tools. Our additional planned actions include:
- E-learning Business ethics mandatory every two years for all white-collar employees
- E-learning Competition law mandatory every two years for all employees in the most risk- exposed areas
- Direct Business ethics trainings (virtual or face-to-face) mandatory every three years for managers level 1- 4
- Direct Competition Law trainings (virtual or face-to-face) mandatory every three years for managers and employees in the most risk-exposed areas