improving transparency and anti-corruption

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Improving Transparency and Anti- corruption Finn Adser, CSR Manager

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Improving Transparency and Anti-corruption. Finn Adser, CSR Manager. DONG Energy is one of the leading energy groups in Northern Europe. We are headquartered in Denmark. Our business is based on procuring, producing, distributing and trading in energy and related products in - PowerPoint PPT Presentation

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Page 1: Improving Transparency and Anti-corruption

Improving Transparency and Anti-corruption

Finn Adser, CSR Manager

Page 2: Improving Transparency and Anti-corruption

We fight corruption

Page 3: Improving Transparency and Anti-corruption

DONG Energy is one of the leading energy groupsin Northern Europe. We are headquartered in Denmark

Our business is based on procuring,producing, distributing and trading inenergy and related products in Northern Europe.

We have approximately 6,000 employees and generated DKK 57 billion (EUR 7.6 billion) in revenue in 2011.

EXPLORATION & PRODUCTION

WIND POWER

THERMAL POWER

ENERGY MARKETS

SALES & DISTRIBUTION

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Page 4: Improving Transparency and Anti-corruption

DONG Energy’s Commitment – anti-corruption

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UN Global CompactSigned in 2006

EITISupporter in 2011

Code of Conductfor suppliers

Policy "Good business conduct"

External Internal

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Co-founder of Bettercoal Launched in April 2012

Responsibility policy

Page 5: Improving Transparency and Anti-corruption

DONG Energy’s Governance

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Policy "Good Business Conduct"

Business Ethic Committee

Guidelines

Controls

Investigate cases

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Whistleblowing

Audit & Risk Committee

Board of Directors

Page 6: Improving Transparency and Anti-corruption

E-learning

"Acting Responsibly"

DONG EnergySetting anti-corruption on the agenda – version 1.0

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Gifts and entertainment

Sponsorships

Facility payments

Trading partners

Fair competition

Personal integrity

Internal controls and financial

reporting

Gifts and entertainment

You are a manager in Sales & Distribution.One of your

sales staff asks for authorisation to invite several

employees of a key customer for dinner at an expensive

gourmet restaurant with a view to getting to know them

better. Coincidentally, on the same day, one of your

administrative employees requests permission to accept

a similar dinner invitation from a supplier of consulting

services.

WHAT DO YOU DO?

A Authorise both invitations because you consider

networking important.

B Authorise your salesman to invite employees of the key

customer, provided this does not violate the customer’s

company policy. You do not authorise the invitation to

the administrative em-ployee, because the invitation

does not appear to be business-related.

C Authorise neither of the invitations.

Fair competitionA marketing consultant has gained access to confidential pricing strategy information from one of our competitors. The consultant offers to sell the information to us.

HOW SHOULD WE REACT TO THE CONSULTANT’S OFFER?A We could purchase and use the information.B We should ignore the offer.C We should ignore the offer and inform the competitor of

the situation.

Page 7: Improving Transparency and Anti-corruption

Growth and new regulation

Need for review

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

DONG EnergyGrowth and new regulation - Anti-corruption version 2.0

Risk Assessment

Proportionate procedures

Top level commitment

Risk assessment

Due diligence

Communication and training

Monitoring and review

Page 8: Improving Transparency and Anti-corruption

DONG EnergyGrowth and new regulation - Anti-corruption version 2.0

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Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Risk Assessment

Conclusions from risk assessment:• "Consistent view on anti-corruption around the organisation"• "sound basic level of protection"• "important to track the risks going forward as you develop operations outside

of current domains"

Recommendations from risk assessment:• Update Policy• Design and implement a risk-based due diligence process in relation to

business partners and employees• Complete framework of internal controls addressing risk of bribery

Page 9: Improving Transparency and Anti-corruption

Bettercoal – a new sectorial initiative

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Mission; to improve the corporate responsibilityin the coal supply chain

Launched 18th April 2012

Page 10: Improving Transparency and Anti-corruption

Bettercoal

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Sectorial initiatives and collective action. Puerto Vallarta, Mexico

The next steps

Develop Code• Based on other standards and best practices• Includes Bribery and Corruption

Assessment:• Self-assessment • On-site assessment by 3rd party• Bettercoal Assessment Database

Page 11: Improving Transparency and Anti-corruption

Our experience

E-learning - Mandatory for all

Regulation vs. volunteer initiatives

Collective initiative (Bettercoal) Long preparation time Risk of failure – critical mass Competition law – not everything is possible

Sectorial initiatives and collective action. Puerto Vallarta, Mexico

Page 12: Improving Transparency and Anti-corruption

Sectorial initiatives and collective action. Puerto Vallarta, Mexico?