Patria Oyj

Based on public information, there is evidence that the company has published statements from the CEO supporting the company’s ethics agenda. In a statement on the company website the CEO identifies the development of ethical conduct as the most important area for improvement and states the company’s zero-tolerance approach towards corruption. The CEO provides the introduction to the Ethical Code of Conduct and in the 2013 Annual Review the CEO discusses the company’s ethical initiatives throughout the year. Similarly in a video message the Chairman highlights the company’s zero tolerance policy towards corruption and unethical activity.

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong, personal, external facing commitment to the ethics and anti-corruption agenda. This personal engagement could include public speeches or involvement with industry anti-corruption initiatives.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. This could include speaking at training events or chairing a review of the company’s anti-corruption programmes.

Based on public information, there is no readily available evidence that the company publishes a statement of values representing high standards of ethical business conduct. The company’s values only reference trust with regard to creating success. Despite the company clearly expressing its commitment to high standards of ethical business conduct in its Ethical Code of Conduct, the document does not contain a statement of values.

Based on public information, there is evidence that the company is a signatory to the UN Global Compact and the ASD Common Industry Standards. The company is a member of the corporate responsibility network, Finnish Business & Society, as well as the UN Global Compact Nordic Network.

Based on public information, there is evidence that the company has appointed the Audit Committee, with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee must oversee and direct operations, to ensure compliance with regulations and ethical principles.

Based on public information, there is evidence that the company has appointed the Chief Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. The Chief Compliance Officer is identified as Hanna Kyrki. Kyrki sits on the Management Board and has a direct reporting line to the Board of Directors.

Based on public information, there is evidence that the company regularly reviews components of its ethics and anti-corruption programme. The Board of Directors receives reports on corporate responsibility and the Audit Committee review issues relating to ethics and compliance. The company therefore scores 1. To score higher the company would need to provide evidence of a major, periodic, heavyweight review of its ethics and anti-corruption agenda, which takes place at least annually.

Based on public information, there is some evidence that an 18-month rolling action plan is the basis for the review of the ethics and anti-corruption agenda. In the 2013 Annual Review the company identifies a number of ethics and anti-corruption activities conducted in 2013, focus areas for 2014 and goals for 2015. However, it is unclear if this forms the basis of the 18-month rolling action plan. Evidence also shows that the company monitors training on ethical conduct and has implemented a number of improvement plans across its ethics programme, including the introduction of online training and the update of the Ethical Code of Conduct. The company therefore scores 1. To score higher the company would need to provide further evidence of the formal, written plan on which the review of its ethics and anti-corruption agenda is based.

Based on public information, there is no readily available evidence that the company has a formal process to review and where appropriate update its policies and practices, in response to instances of corruption. Evidence indicates that in recent years the company has implemented a number of improvement plans to its ethics programme, including the introduction of online training and the update of the Ethical Code of Conduct. However, it is unclear if these updates were in response to actual or alleged instances of corruption. TI notes that in 2014 the company intends to implement a risk assessment looking into serious misconduct.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company has a risk management process, under which ethics and compliance form part of the internal control process. However, there is insufficient evidence to determine if corruption is an identified risk and that the procedure is comprehensive and effective.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its agents. Checks are made on factors including the agents’ backgrounds, reputation and ownership structure. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.

Based on public information, there is no readily available evidence that the company has contractual rights and processes to control and audit agents, with respect to countering corruption. The Ethical Code of Conduct is applied to all business partners and related training is provided if necessary. Partners are supervised and the company requires that business partners abide by the local legislation of any country in which they operate. However, there is no evidence of formal processes to prevent or deal with violations, as the Ethical Code of Conduct states that only employees are subject to disciplinary procedures.

Based on public information, there is evidence that the company ensures contractors, sub-contractors and suppliers are aware of its stance on bribery and corruption. The company states that it only works with suppliers who are willing to abide by the principles underlying its Ethical Code of Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of contractual rights to apply sanctions in the event of contract violations.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimise corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including bribery, conflicts of interest and gifts.

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero-tolerance.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and third parties. The Ethical Code of Conduct is distributed to all company sites and is available on the company website in English and Finnish.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties. The Ethical Code of Conduct is written in clear, comprehensible language.

Based on public information, there is evidence that the Ethical Code of Conduct applies to all company employees, directors and officers.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. All employees are instructed to avoid any activity that may lead to a conflict of interest. The supplementary Guidelines on Related Parties’ Transactions are provided for employees who exercise decision-making power and Board members. The company therefore scores 1. To score higher the company would need to provide evidence that conflicts of interest are clearly defined to employees and explained using examples.

Based on public information, there is evidence that the company has a policy for the receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Individuals may not receive gifts from stakeholders if they are not compliant with applicable legislation, an ordinary part of business or of moderate value. However, evidence does not show that the company has a policy for the giving of gifts. To score on this question the company would need to provide evidence of a policy that regulates both the giving and receiving of gifts, as well as clear upper limits on the acceptable value of a gift and/or the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is evidence that the company has a policy for the receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. Individuals may not receive personal benefits or gifts from stakeholders if they are not compliant with the applicable legislation, an ordinary part of business or of moderate value. However, evidence does not show that the company has a policy for the giving of hospitality. To score on this question the company would need to provide evidence of a policy that regulates both the giving and receiving of hospitality, as well as clear upper limits on the acceptable value of hospitality and/or the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is evidence that the company prohibits facilitation payments. The company therefore scores 1. To score higher the company would need to provide guidance on how this policy is to be implemented in practice, such as when facilitation payments are demanded under duress.

Based on public information, there is evidence that the company prohibits political contributions.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or that it discloses the issues on which it lobbies.

Based on public information, there is evidence that the company regulates charitable contributions. Charitable donations and sponsorship are regulated by the Communications department and the Board of Management. The company therefore scores 1. To score higher the company would need to provide evidence of procedures for donations, such as counter signatures, and that it publically declares recipients.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. The Ethical Code of Conduct does not contain scenarios and is insufficiently detailed to be deemed applicable.

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.

Based on public information, there is evidence that all employees receive anti-corruption training.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

Based on public information, there is evidence that the company provides tailored ethics class-room training for employees in sensitive positions. This includes marketing, sales, procurement, and groups working with customers and stakeholders.

Based on public information, there is no readily available evidence that the company has a clear and formal process for employees to declare conflicts of interest. For business transactions that involve a party connected to an employee, employees must report the matter to their superior and the party responsible for the preparation of the transaction. To score on this question the company must instruct employees to declare conflicts of interest in writing either to a manager or to an independent department.

Based on public information, there is evidence that the company has a commitment to apply disciplinary procedures to those individuals found to have violated its Ethical Code of Conduct, which includes an anti-corruption policy.

Based on public information, there is evidence that the company has multiple, well-publicised, secure channels through which employees can report concerns or suspected corrupt activity. Employees can discuss concerns or questions with their superior, the company management, the General Counsel, the legal counsels, or a via a designated e-mail address. In particular, feedback can be provided anonymously using the Report Alleged Misconduct link found on the company intranet. The company therefore scores 1. To score higher the company would need to provide evidence of an independent reporting channel.

Based on public information, there is evidence that whistleblowing channels are available to all employees, in all geographies. Employees can discuss concerns or questions with their superior, the company management, the General Counsel, the legal counsels, or via a designated e-mail address. In particular, feedback can be provided anonymously using the Report Alleged Misconduct link found on the company intranet.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms, to assure itself that whistleblowing by employees is not deterred or that whistleblowers are treated supportively.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. Employees can discuss concerns or questions with their superior, the company management, the General Counsel, the legal counsels, or a via a designated e-mail address.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.