Monitoring of threats

Ethics management Monitoring of threats Compliance with law Strategy objectives for the years 2016-2020
GRI:

The key risks associated with corruption or bribery are primarily related to the business, legal, financial and reputation areas. Monitoring of the compliance with rules and controls are conducted by the Office of Internal Control, and supervised by the President of the Management Board. The Office of Internal Control is responsible for the identification and analysis of risks in the Group, prevention of factors causing them. At the same time, it examines the activity of particular organisational units and companies in the Group. In the case of completed investments, the Office analyses the contract performance process, use of owned resources, draws up reports and issues instructions to take corrective actions. According to the implemented Procedure IO-01-01-03 “Final Contract Settlement”, after the completion of each construction project, the Office of Internal Control personnel inspects final settlements regarding construction materials purchased and used.

All key projects are analysed with regard to the corruption risk. The special form is filled by 100% of the controlled entities1. In turn, inspections on contracts of lower value are ad hoc and random. A post-inspection report does not disclose tools used for their monitoring, considering them confidential. Disclosure of such information, in particular regarding the method of analyses, according to the Group, could contribute to the reduction of their effectiveness and increased risk of unethical conduct. Risk monitoring is conducted in monthly, two weeks' or, if necessary, weekly cycles.

The Office of Internal Control may also carry out additional inspections. The role of this Office is also to take preventive actions and build the Budimex employees' awareness with regard to the risks and activities that may lead to them. To this end, the Office of Internal Control has also prepared the guide for the Contract Director/Manager, describing production processes allowing for safe and correct contract performance in Budimex SA based on applicable procedures and instructions. In addition, all Budimex employees and suppliers must familiarise themselves with the anti-corruption policy and procedures. All employees - newly hired and with many years of experience in the Budimex Group, become familiar with applicable anti-corruption procedures during regular training sessions.