Patria Group's objective is to be recognized as an ethical operator in the industry, which requires the following:
- Patria's principles regarding ethical business conduct and anti-corruption and anti-bribery measures it takes have permeated the company's stakeholders, with Patria being viewed as a company with high integrity, transparency and ethical standards
- Patria's business partners conduct business based on a level corresponding, at minimum, to the principles and requirements that are specified in Patria Ethical Code of Conduct
- Patria's board members, directors, officers, personnel and temporary workers are aware of the Patria Ethical Code of Conduct and Patria's requirements for ethical business
Patria requires zero tolerance towards corruption and bribery. Patria does not tolerate unethical or corrupt conduct by its board, directors, officers, personnel, temporary workers or business partners and acts actively against it. Patria pays special attention to integrity and strict ethical standards in business conduct with private companies, political parties, public authorities and agencies and their officials in all countries where we conduct business. Patria expects similar ethics and integrity standards from its business partners.
Commitment to anti-bribery and anti-corruption with Patria is authorized and endorsed by the Patria Board of Directors and the President & CEO as well as other senior leadership. This commitment is communicated both internally and externally by the Board, President & CEO and other senior leadership.
Patria's anti-bribery and anti-corruption policy is expressly stated in the Patria Ethical Code of Conduct which is publicly available. Patria Ethical Code of Conduct is applicable to Patria board, directors, officers, managers, personnel and temporary and agency workers in all Patria companies. In addition to the Code of Conduct, Patria has several guidelines for more detailed instructions, such being Public Relations (with e.g. monetary values for gifts and hospitality), Sponsoring, Lobbying, etc.
Management and reporting to the Board and Audit Committee
Patria Board of Directors and Audit Committee is ultimately responsible for the oversight of the company's anti-bribery and anti-corruption programme and regularly reviews reports on the programme's performance, along with the results of internal and external audits, and ensuring that required changes and corrective actions are made.
Patria's anti-bribery and corruption activities are led by the General Counsel & Chief Compliance Officer who reports to the President & CEO. The General Counsel & Chief Compliance Officer report regularly to the Board of Directors and Audit Committee on issues related to anti-bribery and anti-corruption and Patria Ethics and Compliance program. In addition, the main issues regarding the same are reported by the General Counsel & Chief Compliance Officer to the Board of Management of Patria Group. Read more about the management and responsibilities.
Prevention – raising awareness through clear policies and training to ensure ethical decision making and ethical business conduct.
- By training for all personnel and critical business partners as well as offering more in-depth training for specialised groups, read more about the training
Detection – encouraging people to report any concerns or suspected cases of unethical conduct and offering tools to identify potential issues.
- Possibility of Serious Misconduct Survey conducted every other year among the selected members of the personnel.
- Selected stakeholders' survey with explicit questions on possible corruptive activities or other unethical conduct.
- Part of the general personnel engagement surveys, the most recent in 2018
- Stakeholder feedback channel including anonymous reporting possibility via Patria website
- Whistleblowing channel for the personnel including anonymous reporting possibility, read more about raising concerns
Investigations and corrective actions – investigating all reported concerns and taking appropriate corrective action when a case of corruption or other unethical conduct is discovered or suspected
- All reports on alleged misconducts are investigated in accordance with the Patria investigation process. Patria's Chief Compliance Officer who is also General Counsel is responsible for the investigation process together with the top management. First, the Chief Compliance Officer evaluates the nature and gravity of the reported, alleged or suspected unethical conduct. Depending on the case, appropriate resources (such as field experts and/or HR specialists and/or an internal or external auditor) are engaged in the investigation. In serious cases of misconduct, i.e. serious health or life risks, bullying, sexual or other harrasment, serious and continuous improper behaviour, corruption, breach of tax regulations, fraud, embezzlement, inside trading, crime against the enviroment or any other criminal activity, appropriate external professionals or authorities are contacted to guarantee the independence and quality of investigation. All the reports, the steps taken to investigate, and the outcome of the investigations are recorded in a special report log. The results are communicated to the reporter in case the report has not been anonymous. The current whistleblowing system has not allowed communication with anonymous reporters. The reporter is asked to leave contact information in case reporting on investigation is required. A new SpeakUp system is to be taken into use allowing communication with the whistleblowing reporter.
- All reported concerns and unethical conduct incidents are reported to the Audit Committee. Serious cases are reported immediately and the investigations and corrective actions are followed up on by the Committee more frequently and as is appropriate depending on the nature of the case. Other (non-serious) concerns/incidents are reported to the Audit Committee regularly twice a year in a manner that the privacy regulations are met.
- There has not been any serious reported cases in 2018 (and therefore no investigations) concerning Patria personnel, suppliers, business partners or stakeholders. In case of serious incidents involving third parties (such as agents or intermediaries), the proceedings would in most cases be public, further taking into account requirements of the GDPR and any other confidentiality obligations. Patria reports the results of the proceedings if they are public annually in its Annual Report.
Interaction – collaborate with others in our industry to promote wider adoption of anti-corruption and anti-bribery measures, read more about the network.
Ethical and compliance requirements concerning collaboration with third parties
Patria's Code of Conduct states that in addition to personnel, the agents, consultants, intermediaries, market representatives, service providers and other business partners that Patria engages with all represent Patria and act for or on behalf of Patria, and they are therefore expected to conduct their business in a way that meets high ethical standards. They are expected to comply with local legislation in all countries in which they operate.
In addition to what is stated in the Patria's Ethical Code of Conduct, Patria has a Business Partner Management Guideline and Process. This Guideline and the process regulate how Business partners are evaluated (incl. financial, ethical, anti-corruption, reputational, compliance evaluation and integrity due diligence screening) and appointed. The evaluation and appointment process is transparent, authentication is consolidated, measured and traceable, and the partners are supervised. In these Guidelines, Patria reaffirms its zero tolerance for corruption and bribery. Patria does not accept unethical or corrupt behavior by its directors, managers or employees and expects similar compliance and ethical business conduct from its business partners, such as agents, consultants, intermediaries, service providers and joint venture partners.
A documented Integrity Due Diligence is conducted when engaging and re-engaging third parties. It focuses on identifying risks not normally revealed through preliminary background screening. Typical areas of analysis include, for example, beneficial owners, questionable business practices, market reputation, negative media coverage, any political associations that may be of concern, regulatory violations and litigation history.
The scope of the Integrity Due Diligence considers the context in which third parties would be engaged, including the type and profile of Business Partner, type of potential cooperation, scale, geography, Transparency International country corruption risk ranking, planned interaction by the third party with public officials, etc. The Due Diligence takes into account Patria's exposure to legal, corruption, financial and reputational risks. If the potential Business Partner represents an intolerable, uncontrollable and non-remedial risk, any transaction with such Business Partner shall not be executed.
Similar procedures regarding Integrity Due Diligence is conducted when engaging with Joint Ventures, to evaluate the ethics and anti-corruption program or maturity of the potential Joint Venture partner and to evaluate the risk level. In the agreements with a Joint Venture partner, anti-corruption and ethical business conduct will be clearly stated as a precondition for entering into a Joint Venture and continuing cooperation with the same.
Guidelines on gifts and hospitality
Patria has guidelines on gifts and hospitality which indicate Patria's zero tolerance for corruption and any violation of regulations defining third-party relationships. Patria guidelines cover business-based gifts and hospitality that are offered to or accepted from customers, business partners, suppliers or any other cooperation partners. The main content of the guidelines is described below.
Patria and its employees and managers shall not give, offer or promise any undue benefit, gifts or hospitality which may influence on public official's actions or which could be interpreted as an aim to gain business advantage from the business partners. Correspondingly, undue benefit, gifts and hospitality may not be accepted by Patria's employees or managers. Patria requires that its business partners comply with guidelines similar to Patria's anti-corruption policies.
When determining whether gifts and hospitality are reasonable and appropriate to either receive or to give, offer or promise, the value thereof, the reason why they are offered or given, and the nature of the gift and hospitality must be taken into consideration.
Patria does not give, offer or promise, and Patria employees and managers may not accept, any gifts or hospitality
- which are not clearly relevant to Patria's business operations,
- the value of which exceeds the monetary limits set by Patria,
- which constitute pure entertainment without any significant business-related content,
- which consist of cash or the equivalent, such as gift cards or vouchers,
- in any situations in which may appear as an attempt to influence or gain benefits,
- if they violate local laws, or
- if they are offered even when it is known that the recipient may not accept such gifts or hospitality.
Euro-denominated maximum limits applied by Patria are 50€ for gifts and 100€ for hospitality. The number of gifts or hospitality repeatedly extended to the same person has been restricted to four times a year. Gifts and hospitality, the value of which exceeds these amounts, are documented in a specific register which is monitored regularly.
Patria's marketing efforts are often targeted at public procurement involved authorities and users who are related to the national defence forces. Patria has a special responsibility to guarantee an appropriate conduct in all its operations and marketing in order to avoid any suspicion of using inappropriate means in its business operations and relationships with public officials. The gifts and hospitality offered to public officials must always be considered with due diligence. The gifts and hospitality that could affect the actions of a public official may not be given, offered or promised.