Leadership of the company ECO-INVESTMENT, a.s. in agreement with the act n. 418/2011 Sb. about criminal responsibility of a legal person as subsequently amended (hereinafter referred to as “act”) proclaims in the interest of the company and its employees following Compliance programme.
Criminal act is for the purpose of the Compliance programme defined as an illegal act committed within the bounds of the company, if this act is carried out by:
- Statutory body or a member of statutory body or another person in leading position within the company, which is authorised to act in the name of the company.
- A person in leading position that carries out managing or controlling activity, even though this person is not mentioned in a.
- A person having a decisive influence in the company management, if his action made a condition for the origin of the consequence that led to the criminal responsibility of the company, or
- Employee or the person with a similar status while performing a work task, even though this person is not included in a. to c. above, once it is possible for the company to ascribe him.
Corruption is for the purpose of the Compliance programme defined as an action characterised by an abuse of position or function for the personal benefit, which is incompatible with legal code, ethical law, and leads to the detriment of company.
The company made a decision to approach the Compliance programme, the purpose of which is:
- a) Minimise corruption risk in the business activity of the company
- b) Have a preventive effect against corruption risk in the company while providing products and service for the company
- c) As an important company of Czech industry , to serve as an example how to proceed in corruption prevention and unethical behaviour
Simultaneously, it proclaims that:
- a. It will not tolerate any form of criminal act
- b. b. All the people with any responsibility and employees of the company follow the legislation of the Czech republic as well as the internal organization and managing acts of the company /ORA/
- The company disposes of the Compliance programme to prevent criminal responsibility
- The company makes all the possible efforts to prevent any acts of a natural person that can be attributed to the company according to the enactment §8 of the law. The effort to prevent any criminal responsibility of the company is a part of its policy and ethical code
- Compliance programme was formed primarily for the purposes of prevention of the criminal responsibility and corruption and for the managing and controlling setting of the company
- Compliance programme is not a one-time provision. It is a continuous system of prevention against criminal responsibility and corruption in the company
- Compliance programme is evaluated and regularly updated
- The basis of the Compliance programme is the ethical code of the company which is binding for all the people with any responsibility and employees in the company
- i. The company prepared a mechanism for the identification of criminal-law, corruption and other risks, and it calls upon its employees to profit from it for the expression of their worries as well as for the acceptation of the submission about established risks
Compliance programmes contains following components:
- ethical code of the employees
- ethical phone line that serves for an announcement of all the motives leading to the criminal activity, corruption within the company, its activities and employees
- collection of processes and provisions made for the evaluation of criminal-law and other risks and corruption within the company, its activities and employees
Compliance programme concerns all the corporate bodies having a function within the holding structure of the company, to which also belong:
- CentroNet, a.s.
- Trafo CZ, a.s.
- Lagerris a.s.
- REALFINET, a.s.
- Hybernia, a.s.
- Flubio Consulting a.s.