The corporate governance system we have built is a tool that ensures:
This approach enables sustainability for Naftogaz, predictable approaches to doing business and creates opportunities for long-term cooperation with potential investors.
The hotline is a channel for the employees, the contractors of Naftogaz Group and other persons to report the cases of the Naftogaz Group Code of Corporate Ethics violation.
What exactly should be reported via the hotline?
Violations of the Code of Corporate Ethics, including the conflicts of interest among employees, theft and improper use of the Naftogaz Group assets, violations of the Anti-Corruption Program or anti-corruption laws are to be reported. The hotline also accepts health and safety reports, which are reviewed based on the different procedure, compared to the reports referred to below.
What happens next once the notification is received?
Notifications are received by an independent company that picks out irrelevant messages (those that do not apply to the corporate ethics rules). Relevant notifications are processed by the Compliance Office, as well as the Security Office and the Internal Audit Department of Naftogaz Group. The information provided in the notification is verified and analysed engaging the relevant corporate functions and units and obtaining the employees’ explanations. If the reporting person stated no wish to remain anonymous, we may contact him/her for clarification. The internal check or investigation is conducted should there be grounds for it. If the reported violations are confirmed, disciplinary penalties may be taken against the violator.
How long does it take to review the notification?
Our policy is to respond to the notification within 30 days following the date of its receipt.
What are the ways to assist in the notification review?
One shall provide as much actual information as possible about the violation and who committed it and when, in particular:
If the notification does not include the specific information that can be verified, it may be not reviewed. Especially if the notification is anonymous and it is impossible to clarify the details with the person who submitted it.