CZECHOSLOVAK GROUP’s Code of Ethics
One of the key components of the CZECHOSLOVAK GROUP’s anti-corruption program is the Code of Ethics for the holding’s employees who are obliged to adhere to it. Some of its provisions also concern CZECHOSLOVAK GROUP’s partners, e.g. sales representatives and dealers. The CZECHOSLOVAK GROUP Code of Ethics is based on the requirements of the UK-based Transparency International. The Codex includes
- the ban on corruption
- the ban of conflicts of interest
- reporting of corruptive of unethical behaviour
- special duties of sales departments concerning fulfilling the anti-corruption program
- rules of sponsorship and donations to political parties and movements
- the commitment to spread the anti-corruption program beyond CZECHOSLOVAK GROUP
CZECHOSLOVAK GROUP’s Sponsoring Rules
CZECHOSLOVAK GROUP as a socially responsible company in the field of the defence industry logically supports mainly non-profit activities in the regions of the member companies‘ residence. This can mean activities such as sport, cultural, educational or other events. Especially significant are educational events that support the development of technical disciplines which bring major contributions to the national wealth of the Czech Republic, boost the national export potential and are chronically battling a lack of promising students.
The main rule in CZECHOSLOVAK GROUP’s sponsoring activities is that it must not be tied to any specific business opportunities in the public or private sector. Similarly, sponsoring under the circumstances of conflict of interests is also forbidden. Sponsoring activities of CZECHOSLOVAK GROUP are usually publicized either by a press release or by posting the information on the Group’s website or an internal magazine EXCALIBUR.
Support of Political Parties and Movements
The support of political parties and movements by the CZECHOSLOVAK GROUP must be transparent. This support must not be connected to any kind of business opportunity in the public sector. CZECHOSLOVAK GROUP strictly adheres to all legal obligations concerning any potential support of political parties.
Gifts and Hospitality
CZECHOSLOVAK GROUP is providing standard services for their partners in the context of building acceptable professional relationships including the possibility of covering the costs of accommodation during the partners’ stay and extending gifts and courtesies.
However, it is forbidden to provide disproportionately luxurious accommodation, unethical and expensive entertainment of giving gifts with a clearly unreasonable value. These actions are considered potentially corruptive in relation to CZECHOSLOVAK GROUP partners. Similarly, managers and employees of CZECHOSLOVAK GROUP member companies, especially in their sales departments, are forbidden to accept such inappropriate services or luxurious gifts. In case such offers are extended by a partner, the employee is required to report this to their superior.
Facilitation Payments
At some foreign markets, the state employees are allowed to legally require facilitation payments. It is forbidden for CZECHOSLOVAK GROUP companies to provide these payments. The facilitation payments do not include business provisions for private sector partners, e.g. based on dealer agreements, licence agreements or sales representative contracts.
CZECHOSLOVAK GROUP’s Involvement in Offset Programs
While Czech legislation, in adherence to European law, does not further enable Czech companies to participate in offset programs as a part of public contracts of the Czech government and ministries, they can be required to fulfil offset programs when working in foreign environments. A typical requirement, even in democratic countries, can be the partial transfer of production, which can be perceived as a so-called direct offset. CZECHOSLOVAK GROUP in cooperation with their foreign partners carries out the offset programs in strict accordance with national legislation, usually in order to fulfil the customer’s need to gain the capability of partial production and maintenance of the product. CZECHOSLOVAK GROUP refuses and does not participate in offset programs whose aim is to submit contracts not coherent with their activities, which include a risk of corruption and could be abused in order to commit corruption. CZECHOSLOVAK GROUP informs about the activities which can be perceived as direct offsets by standard means while communicating information about the original contract (the production transfer is possible only with the more significant and publicly controllable projects).
CZECHOSLOVAK GROUP’s Ethical Line (ET-LINK)
To create a unified reporting channel for testimonies of unethical, corruptive, illegal, unsafe or environment-damaging behaviour, the CZECHOSLOVAK GROUP holding has created the Ethics Line which can be used by anybody to report the above-mentioned problematic behaviour either in the form of
a) leaving a voice message at telephone number +420 733 678 454, or
b) sending a report to etika@excaliburgroup.cz.
CZECHOSLOVAK GROUP prefers that the reports are not anonymous as such reports themselves pose a risk of unethical behaviour and abuse of the Ethics Line. However, nobody can be forced to leave his name.
The receiver of all reports is the HR department of CZECHOSLOVAK GROUP which in case the report has been submitted by e-mail acknowledges the message’s acceptance and informs the sender within 14 days about the taken steps. After the report has been investigated, the sender is notified about the result.
CZECHOSLOVAK GROUP declares that they value reasonable reports submitted to the Ethics Line. However, this does not apply to false reports with the aim to unjustly accuse another person or company. Such report itself is a breach of the Code of Ethics and CZECHOSLOVAK GROUP’s anti-corruption program with all associated consequences.
