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 a 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 well as offering more in-depth training for special 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 latest in 2018
- Stakeholder feedback channel including anonymous reporting possibility via Patria website
- Whistle blowing 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 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. 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 appropriate external professionals or authorities are contacted to guarantee the independency 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.
- 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 reported serious cases (and therefor 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, however taking into account requirements of the GDPR and any other confidentiality obligations.
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 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.