One of the key components of the ATRAK a.s. anti-corruption program is the Code of Ethics for the holding’s employees who are obliged to adhere to it. Some of its provisions also concern ATRAK a.s. partners, e.g. sales representatives and dealers. The ATRAK a.s. Code of Ethics is based on requirements of the UK-based Transparency International. The Code includes:
- the ban of corruption
- the ban of conflicts of interest
- reporting of corruptive of unethical practices
- special duties of sales departments concerning fulfilling the anti-corruption program
- rules of sponsorship and donations to political parties and movements
- the commitment to spread the anti-corruption program beyond ATRAK a.s.
ATRAK a.s. Sponsoring Rules
The main rule in ATRAK´s sponsoring activities is that any support must not be tied to any specific business opportunities in public or private sector. Similarly, sponsoring under the circumstances of conflict of interests is also forbidden. Sponsoring activities of ATRAK a.s. are usually publicized either by press releases or by posting the information on the website.
Support to Political Parties and Movements
The support to political parties and movements by ATRAK a.s. must be transparent. At the same time, it must not be connected to any business opportunity in the public sector. ATRAK a.s. strictly adheres to all legal obligations concerning any potential support to political parties.
Gifts and Hospitality
ATRAK a.s. provides standard services for their partners in the context of building acceptable professional relationships including the option to cover the costs of accommodation during their partners’ stays and to extend gifts and hospitality.
However, it is forbidden to provide a disproportionately luxurious accommodation, unethical and expensive entertainment or give gifts of a clearly unreasonable value. These actions are considered potentially corruptive in relation to the ATRAK a.s. partners. Similarly, managers and employees of CSG AEROSPACE member companies, especially in their sales departments, are forbidden to accept such inappropriate services or luxurious gifts. In case such offers are extended by a partner, the employee is required to report this to their superior.
At certain foreign markets, state employees are allowed to legally require facilitation payments. It is strictly forbidden for ATRAK a.s. to provide such payments. Facilitation payments do not include business provisions for private sector partners, e.g. based on dealer agreements, license agreements or sales representation contracts.
ATRAK´s Involvement in Offset Programs
While Czech legislation, in adherence to the European law, does not further enable Czech companies to participate in offset programs as a part of public contracts of Czech government and ministries, they can be required to fulfil offset programs when working in foreign environments. A typical requirement, even in democratic countries, can be the partial transfer of production, which can be perceived as a so-called direct offset. ATRAK a.s., in cooperation with their foreign partners, carries out offset programs in strict accordance with national legislation, usually in order to fulfil customer’s need to gain the capability of partial production and maintenance of a product. ATRAK a.s. refuses and does not participate in offset programs whose aim is to submit contracts unrelated to their activities, which include risk of corruption and could be misused in order to commit corruption. ATRAK a.s. informs about the activities which can be perceived as direct offsets by standard means while communicating information about the original contract (the production transfer is possible only with major, publicly controllable projects).
ATRAK a.s. Ethics Line (ET-LINK)
To create a unified reporting channel for testimonies of unethical, corruptive, illegal, unsafe or environment-damaging behaviour, ATRAK a.s. member of CSG holding has created the Ethics Line which can be used by anybody to report the above-mentioned problematic behaviour in the form of sending a report to etikaMczechoslovakgroup.cz.
ATRAK a.s. prefers that the reports are not anonymous because as such, they pose a risk of unethical behaviour themselves and abuse of the Ethics Line. However, nobody is forced to leave his/her name.
The receiver of all reports is the CSG AEROSPACE HR department. If a report is submitted by e-mail, the HR acknowledge the acceptance and inform the sender within 14 days about the steps taken. After the report has been investigated, the sender is notified about the result.
ATRAK a.s. declares that they value reasonable reports submitted to the Ethics Line. However, this does not apply to false reports submitted with the aim to unjustly accuse another person or company. Such report itself is a breach of the Code of Ethics and ATRAK´s anti-corruption program with all the associated consequences.