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CMS of Metrostav a.s.
Metrostav a.s. proudly asserts its status as a modern, successful company for which shaping corporate culture and compliance is an indispensable part of its long-term strategy. We believe that our efforts in this area will effectively reduce the risk of unethical or illegal conduct and improve the overall perception of our company internally and externally.
Metrostav a.s. has long had a comprehensive compliance management system (CMS), which aims in particular at preventing, detecting and responding to conduct that may be considered unethical, illegal, contrary to good morals or company rules, as well as contrary to our corporate culture.
Since 2015, the basic pillar of CMS has been the Criminal Compliance Programme (CCP), referred to as the Metrostav CCP Programme, which also includes an anti-corruption management system. The purpose of the CMS is to prevent illegal and other unfair conduct in Metrostav a.s. with an emphasis on already identified risks (e.g. conflict of interest or corruption).
Following actions that caused the criminal proceedings against Metrostav a.s., we have also introduced a number of technical, organisational and/or personnel measures within the self-cleaning process to remedy the consequences of criminal activities or misconduct and to prevent future violations.
In early 2022, the CMS was updated to meet the requirements of ISO 37301 Compliance management systems and ISO 37001 Anti-bribery management systems. In April 2022, Metrostav a.s. successfully received certification of its CMS compliance with the ISO 37301 Compliance management systems standard and its anti-corruption management system with the ISO 37001 Anti-bribery management systems standard.
Metrostav a.s. considers the CMS to be an integral part of its management system and all its activities and implements a number of measures to ensure and further develop the necessary CMS standard.
Key elements of CMS
Emphasis on leadership
The topic of compliance and corporate culture is a priority at Metrostav a.s. Compliance also plays a strategic role in the company's business activities. The top management sets the "tone from the top down" and within the corporate culture the importance of compliance is actively promoted both internally (e.g. via the Metrostav Group intranet, through training, the internal Metrostav magazine, etc.) and externally (e.g. via the Metrostav Group website and public speeches by the top management of Metrostav a.s.).
Compliance officer and his team
Supervision of the functioning of the CMS of Metrostav a.s. has been entrusted to a separate position of compliance officer (COF). The COF is appointed by the President of the Metrostav Group and reports directly to him as a representative of the company's top management.
Integrated risk management system
Metrostav a.s. has implemented an integrated risk management system. The company pays particular attention to corruption and conflict of interest risks, which it automatically ranks among its "top risks". Metrostav a.s. has created a rating scale to assess the risks.
Internal regulations
In the area of CMS, Metrostav a.s. has a system of organisational management documentation in place, the purpose of which is mainly to prevent, detect and respond to unethical or illegal actions and actions in violation of the company's rules (in particular the Code of Ethics, Our Way of Management and Work, Compliance Policy, OŘN CPR, CMS Manual, etc.). This internal documentation is made available to Metrostav a.s. employees in accordance with the relevant ISO standards.
Code of Ethics
The principles of ethical behaviour and conduct of Metrostav a.s. are set out in the Code of Ethics of the Metrostav Group (the Code of Ethics). The Code of Ethics sets out binding rules of conduct and behaviour for the Group companies, its employees, associates and members of the Metrostav Group companies' bodies. The Code of Ethics declares in particular the following principles of Metrostav a.s. - strict compliance with the law, intolerance of corruption, bribery or unfair competition, social responsibility, emphasis on human rights, inadmissibility of discrimination, inadmissibility of conflict of personal interests and intolerance of non-compliance with the moral principles of the Metrostav Group.
The Code of Ethics of the Metrostav Group is freely available on the Metrostav Group's intranet (http://skupina.metrostav.cz) and internet (https://www.metrostav.cz/cs/o-spolecnosti/eticky-kodex-a-eticka-linka) sites.
Ethics Line
Metrostav a.s. has introduced a whistleblowing system that enables and guarantees employees and third parties anonymous and confidential reporting of unfair conduct through the Ethics Line. The Ethics Line is available on the Metrostav Group website https://www.metrostav.cz/cs/o-spolecnosti/eticky-kodex-a-eticka-linka. It is also possible to submit a complaint to the compliance officer of the Metrostav Group (by email, telephone and in person).
The company guarantees the protection of persons making a complaint in good faith and the consideration of complaints in accordance with the established procedure and within reasonable time limits. The company also seeks to rectify deficiencies and draws appropriate conclusions in the event of reported breaches of internal regulations.
Training
Employees of Metrostav a.s. are regularly trained in the form of e-learning, including in the area of CCP and CMS. New employees receive training as part of their onboarding. Employees are required to pass a final test to complete the training. The company's training system allows people to obtain proof of training completion and compliance with employee training requirements.
Third party due diligence
Metrostav a.s. performs due diligence on third parties such as business partners and candidates for specific positions.
Continuous improvement of CMS
Metrostav a.s. regularly carries out monitoring to evaluate the effectiveness of the implemented CMS. The CCP programme is discussed twice a year by the company's governing bodies. The basis is the Criminal Compliance Report prepared by the company's management. As a result of the meeting, proposals for improving the system or individual measures to strengthen criminal compliance were approved.
To continuously improve CMS, compliance targets and criteria for their evaluation are set. The targets are set annually by order of the President of Metrostav Group (CMS programme valid for the year) following the CMS review discussed by the Board of Directors.
