Why is this important?
Ethical conduct is essential for developing a positive reputation and gaining and preserving the confidence of our business partners, clients, and stakeholders.
OMV Petrom Code of Conduct, Code of Business Ethics, and Whistleblowing Platform Directive are part of our core policies and commitments. These are fundamental documents and have been approved by our Executive Board. In 2021, the Whistleblowing Platform Directive has been updated to address all areas relevant for OMV Petrom activity, in accordance with the provisions of EU Directive 1937/2019 on the protection of persons who report breaches of Union law (the Whistleblowing Directive). We also have the OMV Petrom Compliance Management System fully operational. Through training and compliance programs for targeted OMV Petrom employees, we strive to raise awareness of business ethics.
We constantly monitor the level of training of the people who work for us, and we keep a close watch on potential conflicts of interest.
In order to avoid, monitor, and detect potential lapses in business ethics and to foster a business ethics culture inside the firm, OMV Petrom has a fully operational compliance management system that consists of internal rules, processes, and controls. The compliance management system gravitates around the Code of Conduct and the Code of Business Ethics.
The OMV Petrom Executive Board has signed both the Code of Conduct and the Code of Business Ethics, and they are both binding in all the countries in which the business 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. Moreover, all OMV Petrom’s employees, including the ones working in OMV Petrom’s subsidiaries in Romania, Bulgaria, Moldova and Serbia and all external staff who work under secondment agreements must comply with the Code of Business Ethics.
In the spirit of the EU Whistleblowing Directive and following its relevant topics such as corruption and bribes, conflicts of interest, competition law, and capital markets law, OMV Petrom created an internal Whistleblowing Directive, which presents how employees and external workers can confidentially and anonymously make a whistleblower complaint.
The Compliance Management System of OMV Petrom is periodically reevaluated and in 2013 and 2017 the System was audited based on IDW PS 980 International Standard, in terms of design, implementation, appropriateness and effectiveness.
Under the EWRM exercise, the risks are reevaluated twice a year.
The entire range of OMV Petrom operations were assessed for risks related to corruption. The risks identified in the assessment of the Compliance Management System are facilitation payments, unlawful gifts and hospitality, unlawful donations, undisclosed conflicts of interests, unlawful activities of intermediaries and lobbyists.
In order to follow our strategy, it is of paramount importance that every single employee is in line with our ethical beliefs and principles. Two of the main training offered are on business ethics and antitrust law.
The compliance team participates in training sessions and workshops to discuss their nation-specific experiences from the whistleblower programs. Workers’ awareness on corporate ethics is raised through the available training and the compliance communication program.
Our planned actions include regular mandatory trainings on business ethics for white-collar employees and mandatory Competition Law trainings for all employees in the most risk-exposed areas via dedicated e-learning applications, as well as direct business ethics trainings for managers (virtual or in-person), and mandatory direct Competition Law trainings for managers and employees in the most risk-exposed areas (virtual or in-person).
In 2022, we worked specifically on:
- Enhancing the awareness campaign on the importance on whistleblowing through the following actions:
- A message from the CEO was sent on the intranet to encourage employees to speak up on unethical conduct
- For easier access to blue-collar employees, an awareness letter was attached to the pay slips every 3 months
- OMV Petrom’s values of trust and integrity were emphasized through the means of an awareness letter sent to all contractors and dealers, also re-iterating the availability of whistleblowing channels
- A dedicated topic on whistleblowing was introduced in the business ethics training
- The Code of Business Ethics was revised to specifically include provisions on money laundering topic
- A new compliance poster was shown on the available info screens
- Making available starting March 2022, a new app for OMV Petrom employees, installed on the company smartphones. The Compliance App aims to support and facilitate the employees’ communication with the OMV Petrom Compliance team. The App provides quick access to the Integrity Platform, and it offers on-the-go access to relevant compliance regulations and documentation, and a simple way to contact OMV Petrom Compliance with questions.
- Launching the renewal campaign on conflict of interest, targeting all the white-collar employees
- Continuing to deliver compliance refresher sessions through our training program with virtual and face-to-face sessions in OMV Petrom and our subsidiaries in Bulgaria, Serbia and Moldova
- E-learning trainings on Competition Law: 43 participants
- Virtual face-to-face trainings on Business ethics: 292 participants
- Virtual face-to-face trainings on Competition law: 156 participants
Spot checks – quarterly spot checks on the topics of conflict of interests and gifts & invitations.
Whistleblowing – zero relevant whistleblower reports in the Integrity platform.
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 2 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.
Incidents of anti-competitive behavior or violations of the anti-trust and monopoly legislation – zero incidents
In March 2022, the new Compliance App was installed on the company Smartphones and was ready to use by the OMV Petrom employees. It provides a user-friendly modern communication channel to facilitate contact with the Compliance team and to send compliance reports or access compliance tools.
Our efforts to develop business ethics awareness among all OMV Petrom personnel through trainings and a compliance communication program show how far we’ve come.
We will continue to provide the following:
- E-learning Business ethics mandatory every 2 year for all white-collar employees
- E-learning Competition law mandatory every 2 year for all employees in the most risk- exposed areas
- Direct Business ethics trainings (virtual or face-to-face) mandatory every 3 year for managers level 1-4
- Direct Competition Law trainings (virtual or face-to-face) mandatory every 3 year for managers and employees in the most risk-exposed areas