Anti-Corruption Programme of REAL TRADE PRAHA a.s.
The main intention of REAL TRADE PRAHA a.s. (hereinafter referred to as the “Company”) is the domestic and foreign procurement of high-quality military technology – in this field we provide military vehicles, weapons and weapon systems throughout the world. A characteristic feature of foreign trade in military material is, in particular, the ability to secure supplies of individual pieces of technology, such as weapons, large-calibre weaponry, ammunition, bombs, missiles, tank technology, toxicology equipment, aircraft, helicopters and spare parts for the aforementioned technology as well as complex deliveries in relatively large quantity in the required quality, including sets of spare parts to ensure maintenance and repairs of the technology.
Specific services are provided by REAL TRADE PRAHA a.s. also for museums and collectors of military technology, to whom it supplies military equipment that is disabled, in full compliance with the legal regulations of individual countries.
The result of the responsible approach of the company is adoption of an internal compact system of rules, procedures and regulations, the purpose of which is the compliance of the required behaviour of employees and other persons with fundamental human rights, general ethical values, morals, legal rule and internationally recognized standards. The Anti-Corruption Programme is a part of the aforementioned system and as such it applies to all employees of the Company, including members of the Company’s bodies and external entities such as consultants, suppliers or agents representing the company (hereinafter the “Personnel”).
REAL TRADE PRAHA a.s. does not tolerate at all any acts of its Personnel that could be considered illegal, corruptive, unethical, unfair or immoral. The Company considers such conduct as reprehensible and unacceptable within the set image of behaviour and conduct.
Why do we implement the Anti-Corruption Programme and what do we want to achieve?
The company strongly and clearly opposes any influence of corrupt behaviour on the decision of its own and of its Personnel. Corruption is not welcome in our Company; on the contrary, it is condemned and there are consequences associated with it, which may lead to termination of further cooperation or operation.
WE SAY NO TO CORRUPTION!
This Anti-Corruption Programme sets out the basic principles and policy of the Company, and it also determines the Company’s opinion concerning the corrupt behaviour of its Personnel. The aim of the Programme is to identify and implement such institutes and processes in the Company that will effectively and actively help fight corruption, will control compliance with the Anti-Corruption Programme and opinions in the Company, and will also identify new and current risks to be responded operationally and flexibly.
In our work, we want to achieve in particular such conduct of our Personnel, which will be fully in compliance with the Programme, and particularly with the idea of the global standard set out in the field of defence and weapons by Transparency International. In our internal regulations we implement such rules to ensure in particular:
- Creating a stable environment rejecting corrupt practices – implementing the rules and principles of combating, detecting and condemning corruption through the entire comprehensive internal system of company regulations,
- A strong personal commitment of specific persons – our senior staff are selected with regard to their personal qualities and taking into account their attitude to corruption and ethical and moral behaviour,
- Setting up effective processes for identification and elimination of risks – the Company implements in its system the processes aimed at regular assessing the up-to-date character, effectiveness and efficiency of the implemented Anti-Corruption Programme, such as regular Compliance Team meetings, internal audits, Programme compliance checks, etc. which are immediately evaluated and, based on the results, corrective measures are subsequently taken as a response,
- Creating and setting up effective systems for detecting and punishing possible corrupt practices – the Company defines versatile possibilities of whistleblowing corrupt practices that anyone witnesses,
Our Company generally considers any conduct that is contrary to ethical and moral values as a corrupt conduct, when at the same time there is an abuse of an advantage or possibility of either party to gain an unjustified benefit. Corrupt conduct particularly includes for example accepting or offering a bribe, negotiating an advantage or any material and intangible remuneration in connection with the Company’s business and performance of the Personnel’s work activities. Corrupt conduct also means offering any reward, benefit or profit to a public authority that could result in a misrepresentation, or issuance of a decision by the public authority in favour of the Company.
In addition to the aforementioned, the Company hereby declares and represents that the conduct of the Personnel, which directly or indirectly supports the corrupt practices of co-workers and other persons, is equally reprehensible and is considered as corrupt. We also consider as a support any conduct when a member of Personnel knows about the corruption, but does not report it and does not prevent it.
How do we inform our Personnel about the defined Anti-Corruption Programme and our mindset?
The topics of our Company’s anti-corruption policy are, among other things, included in the initial training of the Personnel within the information about the approved compliance programme. Moreover, the Company includes the education concerning corruption and corruption intolerance in a separate training programme dedicated to compliance programme focused on gifts and bribery, with the respective information being available on the Company’s notice boards, or in brochures or flyers.
The Anti-Corruption Programme, the Company’s Code of Ethics, the Code of Conduct in relationships with external entities and contacts for whistleblowing are available on the Company’s website, and compliance with such documents is required and enforced by the Company from its employees.
How can you inform us about unethical, immoral or corrupt behaviour of our Personnel you have witnessed?
In order to combat the corruption that the Company proclaims and requires, the Personnel as well as any third parties who witnessed undesired conduct, have the opportunity to notify the Company’s management using one of the following methods:
- Electronically by email – email@example.com,
- In writing to a box (anonymous) – the box is installed near the entrance of the Company’s establishment,
- Orally by contacting managing staff in meetings,
- By regular mail, etc.
The following information should not be missing in order to process each whistleblowing and ensure operative possibilities of response more quickly:
- Name of the person who committed an act of corruption, or at least the position, date and time when the act took place,
- A detailed description of the act of corruption,
- Evidence of possible corruption, if available (names of witnesses, photographs, records, etc.),
- Any other relevant information specific to the respective situation,
- Name of the whistleblower, unless the whistleblowing is anonymous
The Company does not tolerate any retaliation against the person who is a whistleblower.
Any whistleblowing may also be made anonymously, or with the request to maintain the whistleblower’s anonymity.
The Company absolutely condemns false or perjured accusations or whistleblowing that have been made with the intent to make damage or cause a harm to a third party. Such conduct is considered unethical and will be treated as such.
What measures and institutes are we taking to prevent corrupt practices?
The basic principle of the Personnel’s behaviour, which the Company seeks and supports on the side of its employees, is an active, honest and conscientious attitude to the rules, laws, regulations and internal regulations of the Company. As a part of prevention of occurrence of undesirable situations, the Company adopts measures consisting in compliance with laws and good practices, measures in the area of concluding contracts, measures in the area of managing the Company’s assets, administration measures, measures in the area of hiring new employees and measures in the area of training.
In particular, the Company has implemented the following specific measures in its internal regulations as a part of the aforementioned:
- The obligation of employees to strictly comply with regulations and internal documentation, in particular the Code of Ethics and the Code of Conduct in relations with external entities, has been established,
- An effective and well functioning control system is in place, the sense and purpose of which is to clarify and reveal activities with a potential to be corruptive,
- The obligation to verify business partners carefully and diligently has been established, Code of Conduct for business partners has been defined,
- The obligation has been established to perform random inspections of the Personnel and worksites, systematic inspections and collect questionnaires completed by the Personnel, regular internal audits focused on the results of corrective measures taken and possible risks,
- The obligation of managers to take a motivating and model attitude towards their subordinates has been established, and where corruption is revealed, consistent investigations, evaluation and adoption of measures or sanctions shall be performed
All Personnel of the Company, and particularly those in managerial positions, shall actively promote and adhere to the Anti-Corruption Programme. All Personnel are obliged to comply with the aforementioned rules reflected in the individual measures, are obliged to comply with all laws and legally binding procedures, as well as the technical and similar conditions. Each manager acts in a motivating manner in dealing with their subordinates, puts emphasis on performance of their obligation in an honest and conscientious manner, emphasizes and enforces the importance of protecting the property, goodwill, reputation and prestige of the Company, puts emphasis on the importance of adhering to ethical principles in all work activities, and puts emphasis on revealing, investigating and resolving all cases of suspected corruption.
How the Company assess the functioning of the Anti-Corruption Programme?
The task of internal auditors in evaluation of the compliance programme taking place at least once a year is also to assess the effectiveness and proper functioning of the Anti-Corruption Programme. Areas with a high risk of corruption are regularly investigated to assess whether there are facts indicating existence of corrupt practices.
If the result of the internal audit or regular inspections requires a change in or modification of the current state of affairs, it shall be implemented immediately, operatively and actively. Incorporating correct and effective corrective measures will lead to reduction or revealing possible unjustified anti-corruption actions in the future.
The evaluation of effectiveness of the Anti-Corruption Programme is focused on fulfilment of its individual parts, both qualitatively and quantitatively, on effectiveness of the fulfilment, and on implementation of possible corrective measures.