Metrostav a.s. (“Metrostav” or the “the Company“) as a member and managing body of the Metrostav Group has taken over the system of internal norms that prevented illegal conducts and promoted ethical behavior.
The Compliance System represents an indispensable and necessary part of the corporate governance as well as of all its activities.
Metrostav has a zero-tolerance policy towards corruption and crime. The Company does not tolerate any form of illegal or unethical behavior and condemns such behavior.
Since 1 January 2012, when the Act on Criminal Liability of Legal Persons and Procedure against them (no. 418/2011 Coll.) came into effect in the Czech Republic, the Company has focused on the criminal compliance matters more specifically and firmly.
From June 2015 the Company has had a complex Criminal compliance program including the Metrostav Group Code of Ethics, Metrostav Group Ethical Line, Metrostav Group Specific Internal Norm No. A-5, regular trainings of employees, regular assessment of this program etc.
The Criminal Compliance Program includes:
Code of Ethics of the Metrostav is identical to Code of Ethics of the Metrostav Group. Code of Ethics of the Metrostav Group is a binding document that expresses the moral principles of the Metrostav Group. It sets out the rules of conduct and behavior for the Group companies, its employees and associates. The document translated to several languages and adopted by all members of the Metrostav Group.
Metrostav Group Ethics Line is a tool for reporting incorrect, unethical, or illegal conduct in violation of the Metrostav Group Code of Ethics. Both employees of the Company and third parties outside the Company or the Metrostav Group may submit their complaints through the Metrostav Group Ethics Line, which is available both via the website or a telephone number..
Educational Programs – all employees are trained on Criminal compliance program as well as the Metrostav Group Ethics Line.
Keeping the system current, alive and in awareness – the system is updated on yearly basis and with any new legislation. It is also checked when the Metrostav Group enters a new territory where the legislation might differ from the Czech one.
Criminal Compliance Reports – all members of the Metrostav Group have to produce twice a year and these are reviewed by the Supervisory Boards.
Internal Audit – the internal audit on the Presidium level checks whether all of the above are met and produces reports for the President of the Metrostav Group as well as for the Board.
External Audit - Ernst & Young's “Assessment of the suitability and effectiveness of the Compliance Management System” took place externally. E&Y concluded that since 2016 Metrostav has implemented a number of steps preceding the criminal liability of legal persons. In the given assessment, the developed system of education, training, internal audit, legal prevention and a functioning Ethics Line were highlighted.
Compliance Management System:
Beyond the above mentioned, in turn of 2021 and 2022, the Company has developed sophisticated Compliance Management System, which combines elements of the international standard ISO 37301 (Compliance management systems) with elements of the international standard ISO 37001 (Anti-bribery management systems) and implements these elements in the Company’s organizational and management documentation. In order to achieve the highest level of compliance the top management of the Company expressed its intention in the area of compliance trough the Compliance Policy.
The objective of the Compliance Management System is achieving compliance with the laws, requirements of costumers and interested parties, while setting up prevention, detection and response to conduct that may be considered unethical, illegal or contrary to the established rules of the Company.
Since the creation of the Compliance Management System, the Company has not observed any breaches of this system. This is also the result of regular training of all Company employees in the principles of the Compliance Management System.
At the start of 2022, the Compliance Management System was certified in accordance with ISO 37301 and ISO 37001 standards by the independent certification body.
To ensure oversight of the implementation of the elements of the Compliance Management System, the Company has installed a Compliance Officer (COF) to whom it has delegated the necessary powers in this area. Anybody can contact the Compliance Officer by means of his email address: firstname.lastname@example.org. With the support of this independent authority active on the direct communication line between the top management and the respective bodies of the Company, we aim at achieving the highest level of compliance.