Zero-tolerance policy on fraud and corruption at DTEK
DTEK maintains a zero-tolerance policy to fraudulent behaviour and a strong ‘tone-at-the-top’ to serve as an example across the organisation. DTEK is committed to preventing, detecting and responding to fraud within the organisation.
Implementation of internal regulatory documents and anti-corruption programmes
To mitigate corruption risks, DTEK has established internal regulatory documents (e.g. DTEK Ethics and Business Conduct Code, DTEK Anti-Corruption Programme) and has implemented comprehensive anti-bribery and anti-corruption programmes and controls. These include the Code of Ethics, Conflict of Interest annual declaration, whistleblowing program, controls that allow us to identify illegal activity (namely at the stage of acceptance of counterparties and candidates for employment, during procurement process, acceptance of goods and services, etc.)
Internal control over financial reporting (ICFR) system and use of SAP
Fraudulent financial reporting risks and accuracy and completeness of DTEK accounting records are managed through the internal control over financial reporting system (ICFR) which is based on the Committee of Sponsoring Organizations of the Treadway Commission (COSO) framework. Our financial reporting controls (including those covering the risks of fraud) are duly documented and evaluated on a regular basis. Where ineffective, remediation measures are developed and implemented. To ensure the reliability of financial statements, DTEK uses automated internal systems.
Ensuring accuracy and completeness of accounting records
DTEK has policies and procedures for ensuring the accuracy and completeness of its accounting records, and the timely preparation of reliable financial disclosures. Annual financial statements are audited by an external independent auditor.
Whistleblowing channel for reporting violations
To prevent corruption, fraud, embezzlement, tax evasion, human rights violations or other violations of DTEK’s Ethics and Business Conduct Code, DTEK’s Anti-Corruption Programme, other local regulatory documents of DTEK (policies, regulations, procedures, orders) DTEK created a whistleblowing channel. Indications of possible violations of laws, regulations, DTEK’s Ethics and Business Conduct Code, DTEK’s Anti-Corruption Programme, and similar documents can be reported via special reporting and whistleblowing channel the Trustline.
Preventive approach to fraud risk management
To reinforce a preventive approach to fraud risk management, DTEK implements additional measurements covering all three types of occupational fraud (as per ACFA Fraud Tree): corruption, asset misappropriation and fraudulent statements. These additional measure mentsinclude the fraud risk assessment methodology development, fraud risks identification and assessment and the development of control measures to prevent / detect fraudulent activities.