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Integrated Annual Report 2012
The Culture of Values


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Grupa LOTOS S.A. - Integrated Annual Report 2012

Preventing corporate misconduct


In 2012, we embarked on implementing a LOTOS Group-wide misconduct prevention system. In April of the reporting period, the Grupa LOTOS Board adopted the Misconduct Prevention Policy, which was made available to our employees and external stakeholders. Channels for reporting suspected misconduct were also established, together with adequate organizational arrangements, processes, and educational tools.

Efforts undertaken in misconduct prevention are geared towards devising and adopting such tools as will help the organization develop a resistance to misconduct, including bribery. These themes are addressed in the Ethical Conduct Programme and the Misconduct Risk Management Programme, which together make up the organization's misconduct prevention framework.

Misconduct prevention system
Misconduct prevention system

One component of the prevention system was a pilot assessment for 2011 of the organization’s resilience to misconduct, which is a source of information on how well we are prepared to effectively manage the risk of misconduct. As part of the assessment, the defined processes within Grupa LOTOS were graded, and the choice made as to which of those carry the greatest risk of misconduct in the Company as a whole. This assessment will be repeated periodically to monitor the effectiveness of the preventative measures taken.

Furthermore, reviews of selected process areas are conducted with a view to identifying and potentially modifying measures designed to reduce the likelihood of misconduct, both externally and internally. We also organize training sessions on issues related to counteracting such practices; in 2012, this subject was discussed at length by the management staff in connection with the work on the LOTOS Group’s Code of Ethics.

Percentage of Grupa LOTOS employees trained in the organization’s anti-corruption policies and procedures
Type of position 2010 2011 2012
Management positions 3.5% 8.9% 62.5%
Other positions 3.1% 7.4% 5.7%

Whenever suspected misconduct is reported, an investigation is carried out within the LOTOS Group, the principal goal of which is to collect the information necessary to correctly classify a given occurrence and determine the appropriate basis for action. In the reporting period there was one case of disciplinary action in Grupa LOTOS, concluded with a dismissal on charges of bribery.

In 2012 , no cases were identified when contracts with business partners had not been renewed because of breaking the rules for counteracting corruption.

Misconduct prevention system



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