Code of DTEK Corporate Ethics

1. GENERAL

DTEK is one of the leaders of the Fuel and Energy Sector of Ukraine. We were among the first to bring European standards of business practices to the Ukrainian energy market. To have an impeccable business reputation the Company needs not only professional management, but also continuous strict abidance by the rules and standards of business ethics. The Code of DTEK Corporate Ethics sets forth and summarizes the norms and principles of conduct to be followed by all the employees of the Company referring both to the corporate center and to the enterprises included into the DTEK Group.
 

Terms and definitions:

Company is DTEK.

Code of Corporate (Business) Ethics of DTEK is a set of norms and principles to determine the ethics of relations both inside the Company and between the Company and its partners, counterparties and other stakeholders.

Conflict of interests is a situation when the personal interest of both an employee and his or her relatives impact or may impact the unbiased fulfillment of the employment duties and can lead to conflict between the personal interests of an employee and interests of the Company.

Affiliated persons are physical or legal persons who can directly or indirectly influence making of an employment-related decision by a Company’s employee.

Counterparties are physical persons, institutions and organizations bound by obligations with the Company under a general agreement, and/or cooperating in the course of its fulfillment (clients, suppliers, contractors, investors, etc.).

Difficult ethical situation is a situation in which the moral concepts of an employee, on the one hand, are in collision with the moral concepts of the Company as a whole, on the other hand.

 
Goals and tasks of the Code

The goal of this Code is establishment of the corporate standards of DTEK business ethics and regulation of the actions of the Company’s employees in difficult ethical situations.

The tasks of the Code: 

• to establish the principles of the DTEK corporate ethics on the basis of the Mission, Vision and Corporate Values of the Company;
• to guide the employees in understanding, supporting and observing of uniform principles of business ethics;
• to establish the rules of conduct of the employees in difficult ethical situations.

Application of the Code

In its activity the Company strictly abides by the principles of the business ethics described in the Code. The present Code is worked out on the basis of the legislation of Ukraine and generally recognized principles and norms of business ethics. The Code does not describe all the possible cases and situations that an employee may deal with while carrying out his/her employment-related duties, but contains the main guidelines for solution of difficult ethical situations.


2. PRINCIPLES OF DTEK CORPORATE ETHICS

• The Company builds its activity on the principles of the supremacy of law in all the areas of public and economic life;
• The Company builds relations with its employees on the principles of respect for human rights and personal dignity, equal opportunities for employees;
• The Company builds dialogue and relations with local communities, state authorities and local self-government on the principles of openness, partnership and cooperation;
• The Company builds its relations with counterparties on the principles of honesty, fairness and good faith;
• The Company builds its relations with its competitors on the principles of free and fair competition with strict observance of norms and rules of business ethics;
• The Company does not participate in any political or religious activities;
• The Company is fully aware of its responsibility to the society for preservation of the environment and considers its activity in the area of the environmental protection an essential part of successful business practice and an indispensable condition for achievement of its strategic goals.
  

3. PRINCIPLES OF CORPORATE ETHICS OF DTEK EMPLOYEES

Relations between employees and the Company

The employees build their relations with the Company on the principles of:

• loyalty towards the Company;
• diligent observance and fulfillment of policies, provisions, regulations, instructions and other internal regulatory documents of the Company.

Employees of the Company lay the foundation for its reputation. That is why they must be aware that any unethical and antisocial actions committed at the working place or at spare time can cause damage to the reputation of the Company.

Relations between employees of the Company

Relations between employees of DTEK, regardless of the occupied position or sphere of activity, are built on the principles of:

• mutual respect and assistance;
• openness and goodwill;
• team-based work and focus on cooperation.

Any forms of disparaging or insulting attitude towards each other are not admissible.

Relations between managers and their subordinates

Relations between managers and their subordinates are built on the principles of:

• openness of the management towards its employees;
• provision by managers of equal opportunities to all their subordinates for fulfillment of their duties;
• support of employees’ initiative;
• understanding of the specific character of employees’ work and sharing the responsibility for their performance;
• impartiality and fair assessment of the subordinates’ performance.

Relations between subordinates and managers are built on the principles of:

• respect, discipline and adherence to subordination;
• diligent fulfillment of both their direct employment duties and other assignments of the management not set forth in job description, but directly related to the sphere and specific activity of a Company’s subdivision.

Relations with counterparties

In their relations with counterparties the employees of the Company shall be guided by the principles of:

• respect and goodwill;
• priority of the Company’s interests;
• objectiveness;
• economic expediency.

Employees should not disclose information about counterparties, which can cause material or any other damage to them or to the Company, except for the cases when such disclosure is envisaged by the legislation.

Relations with affiliated parties

Employees of the Company must avoid involvement of the affiliated parties as counterparties. Employees should not participate in making decisions about cooperation with affiliated parties; in case of an operational need for involvement of affiliated parties to cooperation with the Company an employee should address his/her immediate manager.

Confidentiality and disclosure

Employees shall preserve the Company’s commercial secret and keep confidential information obtained during the employment duties.

Public activity

Employees of the Company may conduct any political, religious or public activities not prohibited by law if they are carried out in the time free from employment duties and outside the working place.
 
Employees should not use the name of the Company, financial, material or any other resources of the Company for their political, religious or public activities.

Use of the Company’s resources

Employees should treat the property and other resources provided by the Company with the utmost care and should use them only for employment objectives.

Conflict of interests

Employees of the Company should avoid situations, which can lead to a conflict of personal interests and the Company’s interests:

• receipt of money, gifts or remuneration in any form given in order to influence the course, process and/or result of a business decision made by a Company’s employee;
• use of the Company’s name, reputation, material, financial or other resources, confidential information for personal benefit;
• other situations that can lead to consequences unfavorable for the Company.

In case of a conflict of interests or a possibility of such a conflict an employee of the Company should address its immediate manager for assistance in resolving the situation. If the immediate manager is unable to settle the conflict of interests, an employee is entitled to address a superior manager up to the Chief Executive Officer of DTEK for help.


4. FINAL PROVISIONS

Observance of the Code of Corporate Ethics, responsibility

In their professional activity all employees should be guided by the principles described in the Code of Corporate Ethics; each employee is personally responsible for observance of the Code. If an employee is unable to resolve a difficult ethical situation on his/her own he/she needs to address the immediate manager for advice and help.

A manager is responsible for compliance with the Code of Corporate Ethics by his/her subordinates. He/she helps them to interpret the rules and norms of the ethical conduct correctly, and by own examples demonstrates a high-standard model of business ethics of DTEK employee. None of the employees or managers of the Company has the right to make or approve any action in breach of this Code of Ethics.