Identifying misconduct at an earlier stage is crucial to prevent wrongdoing and harm to the company. Our employees, as well as other stakeholders represent a valuable source of information that can help identify breaches of ethical standards. To this end, the OMV Petrom has introduced several reporting channels:
► business ethics helpline, a telephonic linefree of charge for calls from Romania that is available both internally and externally 24/24;
► a compliance dedicated e-mail address;
► a whistleblower mechanism – the Integrity Platform, a third-party operated tool. Anyone can access it online (omv-group.integrityplatform.org) and report an issue relating to corruption, bribes, conflicts of interest, antitrust law, or capital markets law. The report can be filed anonymously if desired. It will be analyzed, and the answer provided within ten days through the same platform. Identified violations of ethical standards will be handled further by the Whistleblowing Committee. The platform is available in local languages.
The advisory activity provided by the Compliance department represents a core element of organization’s corruption prevention strategy. Advisory expertise is available to the Executive Board, managers and employees in all the areas embedded in the Code of Business Ethics and is accessible by:
► direct contacting OMV Petrom Corporate Compliance Officer and the other members of the Compliance department
► e-mail (firstname.lastname@example.org)
► telephone (business ethics helpline)
All the available advisory and reporting channels/mechanisms are underlined in the Code of Business Ethics in a dedicated section and published both on OMV Petrom intranet and Internet web page.
The importance of consulting the Compliance department whenever in doubt, as well as of reporting non-compliance behaviors is continuously emphasized during the trainings on business ethics matters. On these occasions, the available advisory and reporting mechanisms are re-iterated and employees are encouraged to use them.
Acting in good faith does not lead to any restrictions or negative consequences for employees in their capacity as whistleblowers. Retaliation against anyone who speaks up is absolutely not tolerated.
OMV Petrom’s policy of no-retaliation is communicated to the employees via the Code of Business Ethics and the internal rules related to the Integrity Platform. It is also re-iterated within the business ethics trainings.
To prevent corruption risks related to potential business partners – suppliers, beneficiaries of sponsorship and donations, clients, other types of business partners, OMV Petrom has implemented a third-party check process. The third-party check is done in terms of corruption, money laundering, and other aspects of OMV Petrom Code of Business Ethics. It includes direct and indirect shareholders, ultimate beneficiaries, publicly exposed persons, media coverage. To this end, OMV Petrom requests counterparties to provide information according to a standardized questionnaire. Red flags are defined as connections to government officials, persons, and companies referred to in high attention media reports related to political and corruption cases or any other criminal conduct involvement.
In terms of international trade sanctions and embargoes, a process for screening potential new, as well as existing business partner towards EU and US sanction lists has been put in place at OMV Group level since 2012.
As part of the reporting and monitoring activity, the Compliance department performs quarterly spot checks on the Code of Business Ethics topics, such as gifts & invitations, conflict of interests, third-party ethics checks. Spot checks are directed to those activity areas that are the most exposed to such risks. Apart of due diligence processes and the reporting channels, employee training is an important measure to prevent corruption risks.