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Improving Transparency and Anti-corruption

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

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Improving Transparency and Anti-corruption

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  1. Improving Transparency and Anti-corruption Finn Adser, CSR Manager

  2. 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 in energy 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

  3. DONG Energy’s Commitment – anti-corruption External Internal UN Global Compact Signed in 2006 Policy "Good business conduct" EITI Supporter in 2011 Responsibility policy Co-founder of Bettercoal Launched in April 2012 Code of Conduct for suppliers Poli Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  4. DONG Energy’s Governance Policy "Good Business Conduct" Business Ethic Committee Board of Directors Audit & Risk Committee Guidelines Controls Whistleblowing Investigate cases Poli Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  5. DONG EnergySetting anti-corruption on the agenda – version 1.0 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 competition A 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. Gifts and entertainment Fair competition Sponsorships Trading partners Facility payments Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  6. DONG EnergyGrowth and new regulation - Anti-corruption version 2.0 Monitoring and review Communication and training Growth and new regulation Need for review Proportionate procedures Due diligence Top level commitment Risk assessment Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  7. DONG EnergyGrowth and new regulation - Anti-corruption version 2.0 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 Poli Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  8. Bettercoal – a new sectorial initiative • Mission; to improve the corporate responsibilityin the coal supply chain • Launched 18th April 2012 Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  9. Bettercoal 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 Poli Sectorial initiatives and collective action. Puerto Vallarta, Mexico

  10. 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

  11. ? Sectorial initiatives and collective action. Puerto Vallarta, Mexico

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