Ethics and compliance

Our Ethics and Business Conduct Code (the “Code”) is a fundamental document setting up the principal provisions of DTEK's internal regulatory system. Among others, it establishes the rules of ethics and business conduct that must be followed by all DTEK employees. The Code outlines the way employees should act at all times, inspired by DTEK Group’s mission, vision, and corporate values, as well as rules governing ethics and business conduct. DTEK compliance policies, programmes and regulations elaborate provisions of the Code and together constitute DTEK's compliance regulatory framework. We actively train our employees and senior managers to operate ethically and to world-class standards.

A message from Maxim Timchenko, CEO:

“DTEK Group is the largest private investor in the energy sector of Ukraine and has a growing presence in Europe. The combination of efficient production processes and open, responsible, and ethical business conduct is vital in successfully implementing our development plans and helping us to maintain our leadership position. Honest and ethical conduct by each employee is central to the company’s success.”

Business conduct:

• DTEK Group builds relations with employees on the principles of respect for human rights, protection of personal dignity, and equal employment opportunities;
• Relations between the employees, regardless of their position or occupation, as well as between the employees and DTEK Group, are based on the principles of honesty, respect and good faith;
• We build relations with counterparties based on the principles of fairness, regulatory compliance, and economic expediency;
• DTEK Group strives to promote the sustainable development of local communities by providing support to the social infrastructure of the regions where we operate and implementing social partnership programmes;
• We engage in dialogue and foster relations with local communities, civil society organisations, governmental authorities, and local self-governments based on the principles of openness, partnership and cooperation;
• DTEK Group strongly condemns any forms of harassment (including sexual harassment), as well as mental and physical abuse (including bullying and mobbing) committed by or against employees.

Our Anti-Corruption Programme (the “Programme”) establishes a set of rules, measures and procedures to counteract and prevent corruption in DTEK Group’s activities.

The Programme has been developed to reinforce the principles of the Code and requires all DTEK Group directors, officers and employees to conduct their activities in full compliance with all applicable anti-corruption laws and regulations.

The Programme is aimed at forming an effective anti-corruption system, preventing the involvement of DTEK Group employees and intermediaries in corruption practices, strengthening business partners’ and the community’s trust in DTEK Group and strengthening DTEK Group’s business reputation. DTEK Group’s compliance with anti-bribery and corruption laws is fundamental to our business conduct. Zero tolerance for bribery and corruption means that all improper payments in dealings with public officials or private individuals are strictly prohibited, as is offering or giving anything of value for a corrupt purpose.

A message from Maxim Timchenko, CEO:

“Our priority is the ethical conduct of business with zero tolerance for corruption in all its forms and manifestations. We have been true to this aim since the very foundation of the company. We have developed this Anti-Corruption Programme in accordance with the best international practices. It is not just a formal document, but an effective tool that enables real mechanisms to counter corruption.”

DTEK has taken its zero-tolerance stance on corruption global by launching the English version of its “Anti-Corruption” training course for employees and partners worldwide. Originally developed in partnership with UN Global Compact Ukraine and over 50 experts, the course has already reached 100,000 employees in Ukraine and is now accessible to businesses everywhere.

In 2025, DTEK translated and integrated the program into its compliance system, reinforcing ethical practices and ESG alignment across its international operations. More than 7,000 DTEK employees have completed the training, which is now available to staff in European offices and to any organisation committed to transparency.

Why it matters:

This interactive course equips businesses with practical tools to identify risks, prevent prohibited practices, and foster a culture of integrity. Topics include corruption risk management, whistleblower cooperation, and leadership accountability.

Oleksandra Moskalenko, Chief Legal Officer at DTEK, said:

“Transparency isn’t optional—it’s the foundation of trust. By sharing these tools globally, we aim to make integrity a daily practice, not just a policy.”

The DTEK Compliance Programme is a Group-wide strategic document aimed at:

• Helping DTEK Group to achieve its strategic business goals of diversifying current geographical exposure and growing internationally;
• Providing information on strategic vectors of the development of the Compliance function that allow it to monitor and control further progress;
• Increasing awareness among the Group’s investors, business partners and other stakeholders about elements of the compliance management system at DTEK Group.

DTEK Group companies conduct their business in strict compliance with sanctions rules and regulations. DTEK Compliance is responsible for performing due diligence checks to ensure that the group companies adhere to applicable sanctions regimes. 

DTEK manages sanctions risk on the principles of:

• Reasonableness and proportionality of measures to mitigate sanctions risk;
• Priority of risk prevention over risk settlement; and
• A risk-based approach in assessing  potential business partners.

DTEK conducts mandatory due diligence of new and existing business partners and to prevent violations of applicable sanctions regimes. 

DTEK employees should avoid actions and situations that may cause a conflict of interest and contradict DTEK’s interests. Employees should avoid gaining personal advantage from business opportunities arising when they perform their duties at DTEK. 

DTEK has established a set of mechanisms to prevent, monitor, investigate and remedy any type of conflict of interest, which include: 

• Mandatory initial disclosure of conflicts of interest by candidates on appointment or taking up a new position at DTEK;
• Mandatory periodic disclosure of conflicts of interest by employees in the course of their employment (typically conducted on an annual basis);
• Ad hoc disclosure whereby employees disclose all relevant information about their actual or potential conflict of interest when circumstances change, after their initial or periodic disclosure has been made;
• Assessment of all situations of conflict of interest (actual or potential) by the Compliance function;
• Implementing risk mitigation measures as may be recommended by Compliance.

DTEK expects employees to adhere to excellent standards of conduct, which include being open and transparent about gifts and hospitality provided or received. DTEK discourages employees from receiving, offering, or giving gifts or hospitality, from third parties, including suppliers and business partners. At the same time, DTEK accepts that occasional modest giving or acceptance of a gift or hospitality may be a legitimate contribution to good business relationships. However, it is essential that they do not influence, nor could be perceived as influencing business decision-making.

Employees must consider whether giving or receiving the gift or hospitality is appropriate and ensure that they are given and received openly and without any attempt to mislead or hide the nature, value, purpose, or identity of the giver or the recipient.

Gifts or hospitality may only be offered to employees or representatives of business partners or prospective business partners if it is reasonable, proportionate (i.e. in line with the recipient’s position in his/her company) and does not contradict the internal requirements of DTEK. The employees must record received or provided gifts and hospitality and receive relevant approvals from internal stakeholders.

According to DTEK’s Ethics and Business Conduct Code, all DTEK employees can report or seek guidance regarding potential or actual misconduct without fear of retaliation.

Contact details of the Trust Line:

• For Ukrainian employees

• For the employees outside Ukraine:

Partnering Against Corruption Initiative

In 2023, DTEK Group joined the World Economic Forum’s Partnering Against Corruption Initiative (PACI) in an effort to smash corruption in all its forms. In becoming a member of the world’s principal CEO-led anti-corruption platform, DTEK Group united with some of the world’s largest and most prestigious companies in a range of initiatives to prevent and combat bribery and corruption. At the same time, DTEK Group will share unique lessons on how companies can tackle corruption against a backdrop of war or instability.

In January 2024, DTEK’s CEO Maxim Timchenko acted as a firestarter for the Vanguard meeting at the Partnering Against Corruption Initiative (PACI) at the 54th Annual Meeting of the World Economic Forum. The Vanguard PACI meeting is an annual convention of global companies’ CEOs, who have pledged themselves to combating corruption and manifesting their companies’ stance and commitment to the principle of zero-tolerance for corruption.

UN Global Compact

In 2007, DTEK Group became a party to the UN Global Compact, the world’s largest corporate sustainability initiative of the United Nations based on CEO commitments to implement universal sustainability, human rights, labour, and anti-corruption principles. In particular, DTEK Group is fully committed to Principle No. 10, according to which "businesses should work against corruption in all forms, including extortion and bribery".