improving transparency and anti-corruption
DESCRIPTION
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 PresentationTRANSCRIPT
Improving Transparency and Anti-corruption
Finn Adser, CSR Manager
We fight 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
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
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
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.
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
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
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
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
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
Sectorial initiatives and collective action. Puerto Vallarta, Mexico?