In DONG Energy, we work in a competitive and challenging environment, even more so as we expand into new markets. As a company and as individuals, we are faced with financial, technical, commercial and human challenges every single day. In order to ensure lasting success, we must respond to these challenges by acting with integrity in our dealings with our customers, suppliers, agents, colleagues and other stakeholders. Through our Good Business Conduct programme we work to systematically ensure good practices across all of our business dealings and in all countries in which we operate.
We have principles and policies that guide our approach to good business conduct:
DONG Energy Way: The foundation for all of our work is the five guiding principles in the DONG Energy Way. One of the principles is integrity, which for us means that we are open and trustworthy and uphold high ethical standards in our business activities.
Sustainability Commitment: We have an overarching policy on sustainability, which we call our Sustainability Commitment. In this, we commit to complying with all applicable laws and regulations and to work against corruption and bribery in all their forms.
Good Business Conduct Policy: We have a policy on good business conduct, which applies to all employees and our board. The policy includes guidelines on anti-corruption, ethical business practices and matters of integrity.
Training and implementation
We conduct training on the Good Business Conduct Policy, which the board and all employees must complete. The training is based on an e-learning platform and it challenges employees on concrete cases regarding ethical business practices. Leadership Forum, which comprises the 400 top managers in DONG Energy, must complete the training every second year.
Control mechanisms and oversight
We have control mechanisms in place to ensure that our procedures are robust:
We carry out an annual legal risk assessment of our most significant legal risks that feeds into our group-wide risk assessment as further described in our annual report. This ensures the continuous alignment of our programme.
Our employees, business partners, suppliers, customers and other persons with an affiliation to us can report serious offences, such as cases of bribery, fraud and other criminal offences, to our whistle-blower hotline. The chairman of the Audit and Risk Committee formed by the Board of Directors of DONG Energy A/S is responsible for the whistle-blower hotline.
Our internal audit department suggests improvements and ways of streamlining our processes and control environment. The department reports to the Audit and Risk Committee, which means that the department is independent of our general management structures.
Our Compliance Committee, which is chaired by our CEO, performs oversight of the Good Business Conduct Programme. The Committee monitors among other things all legal non-compliance cases related to our Good Business Conduct Programme and whistle-blower cases, sponsorships and donations, material gifts and entertainment offered or received by our employees and our various legal compliance projects twice a year.
DONG Energy performance in 2016
In 2016, we had three substantiated whistle-blower cases. Two cases concerned conflicts of interest in connection with external business partners, and one case concerned kickbacks from two suppliers. The cases have had consequences for the involved employees and consultants' employment with us.
None of the cases reported were critical to our business, nor have they impacted our financial results. We look very seriously on such cases and do what we can to avoid that similar cases occur again.