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Ethical business conduct

Introduction

Scatec is opposed all forms of corruption and strives to meet the highest ethical standards across our business activities.

Our Code of Conduct prohibits all forms of corruption, and we implement internal controls to prevent, detect and remedy improper conduct through our and Anti-Corruption Compliance Programme. Our approach is risk-based, and we keep a special focus on markets and activities particularly exposed to corruption.

Management approach

Scatec is subject to national and international laws prohibiting bribery and corruption. All Scatec employees and subsidiaries must comply with the Norwegian Penal Code, the US Foreign Corrupt Practices Act and the UK Bribery Act, all of which have international effect. In addition, Scatec complies with the applicable anti-corruption laws in the countries where we operate.

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Scatec has adopted a set of policies and procedures designed to adequately prevent and detect the corruption risks the organisation faces. The policies and procedures aim to provide Scatec employees necessary guidance to make the right decisions. They are also designed to prevent deliberate unethical conduct by our business partners and suppliers.

The Scatec Governance System consists of procedures that cover a broad range of risks, many of which also includes measures working to mitigate corruption risks. This Anti-Corruption Program provides references to the key procedures in the governance system aimed at preventing and detecting corruption.

The Code of Conduct describes what is expected of Scatec and its employees when interacting with stakeholders and with each other. It sets out the essential requirements for good business conduct and provides guidance on how to act within the Scatec values.

Refer to our Code of Conduct on our corporate website.
Refer to our Anti-corruption programme on our corporate website.
Refer to our Corporate Governance Report on our corporate website.

GRI 205-1

Operations assessed for risks related to corruption

Corruption risk assessments form the basis for selecting the areas that requires specific mitigating actions and resource allocation. Each business unit is required to regularly assess and prioritise corruption risks in their activities. The Global Compliance Officer supports the business unit in their risk assessments and in identifying mitigating measures.

We conduct corruption risk assessments at country, project and contract level. Scatec utilises the assessments to pinpoint areas which require specific attention, mitigating action and resource allocation. When risk is identified, it is recorded and reported to the relevant stakeholders in each project to ensure awareness and implementation. In addition, we conduct a group risk assessment for every business unit each year.

Projects moving from opportunity, development, and structuring to the delivery and power-production phases are assessed through Decision Gates. There are four Decisions Gates with clear criteria and requirements related to screening, compliance and risks of corruption.

Contracting Parties such as business partners, suppliers and corporate customers may expose Scatec to reputational, legal, and operational risk. Scatec is committed to taking the necessary steps to manage the risks arising from third-party relationships.

As part of this commitment, no relationship with a third party may be established without appropriate integrity due diligence (IDD) of the business relationship, and no contract shall be entered into without adequate anti-corruption undertakings. All third party relationships shall undergo sufficient monitoring.

All new third parties, hereunder business partners, suppliers and corporate customers must undergo appropriate IDD in accordance with the Integrity Due Diligence Procedure. The IDD requirements for third parties are risk-based and determined by the risk of the country, the scope of work and the annual value of the contract. The relevant Project Manager from Business Development or Solutions is responsible to ensure that the Integrity Due Diligence Procedure is complied with. Detailed guidance of the Integrity Due Diligence process is described in the Integrity Due Diligence Procedure.

Local development partners and consultants assist in development activities, which often includes interactions with Public Officials and government authorities. These business relationships represent a high risk to Scatec, and is therefore placed under specific control measures: Enhanced IDD requirements, tailored Anti-Corruption clauses, and enhanced monitoring activities.

GRI 205-2

Participation in anti-corruption training and targeted workshops for high-risk groups

Scatec requires all employees to complete training in our anti-corruption policies. We have developed an advanced gamified Code of Conduct training, which is an interactive game consisting of dilemma training and mini games. The course introduces the Code of Conduct and the main procedures adopted to prevent and detect corruption. Employees require an 80% pass rate for each module to be certified on the training platform. The objective of the training is to ensure that Scatec’s employees are familiar with applicable anticorruption laws and are prepared to identify and manage the corruption risks they may encounter while working for Scatec.

All Scatec employees are required to attend the in-person anti-corruption training course every three years. The Global Compliance Officer is responsible for coordinating the anti-corruption training. For employees located on project sites during construction, it is often necessary to coordinate training in the language commonly used on site.

The Global Compliance Officer is responsible to ensure that anti-corruption training is made available in the appropriate language and that the trainer is equipped to provide guidance on anti-corruption laws and the relevant governing documents.

Employees with high exposure to corruption are required to attend tailored anti-corruption training. An analysis is performed every year to determine employees with specific exposure to corruption risk owning to their particular role. Based on these assessments, Scatec has developed specialised workshops for employees working within the departments of Business Development and Solutions. Each business unit is responsible for identifying the Scatec employees with specific training needs, supported by the Global Compliance Officer. The HR function shall support the Global Compliance Officer to effectively deliver training in the locations outside HQ.

The number and percentage of employees that the organisation’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region, is presented in the tables below.

GRI 205-2: anti-corruption policies and procedures

EmployemtEuropeAfricaLATAMMENAAsiaTotal%
Full-time employees212214635875622100%
Short-term employees and consultants485121834162100%
784100%

Scatec’s anti-corruption policies and procedures are communicated to all suppliers and business partner globally. Contracting Parties such as business partners, suppliers and corporate customers may expose Scatec to reputational, legal, and operational risk. No relationship with a third party may be established without appropriate integrity due diligence (IDD) of the business relationship, and no contract shall be entered into without adequate anti-corruption undertakings. All third party relationships shall undergo sufficient monitoring.

All new third parties, hereunder business partners, suppliers and corporate customers must undergo appropriate IDD in accordance with the Integrity Due Diligence Procedure. The IDD requirements for third parties are risk-based and determined by the risk of the country, the scope of work and the annual value of the contract.

The relevant Project Manager from Business Development or Solutions is responsible to ensure that the Integrity Due Diligence Procedure is complied with. Detailed guidance of the Integrity Due Diligence process is described in the Integrity Due Diligence Procedure.

All suppliers must sign our Supplier Code of Conduct and confirm conformance with the IFC’s anti-corruption guidelines which we integrate into all our contracts, in addition to HSSE, environmental, social, and quality assurance and control requirements.

The number and percentage of employees that have received training on anti-corruption, broken down by employee category and region, is presented in the tables below.

GRI 205-2: anti-corruption training

EmploymentEuropeAfricaLATAMMENAAsiaTotal%
All employees25219682669669289%
692 89%

GRI 205-3

Confirmed incidents of corruption and actions taken

GRI 205-3: Confirmed incidents of corruption and actions taken

Confirmed incidents of corruption and actions takenUnitActual 2021Actual 2020Actual 2019
Confirmed incidents of corruptionNumber000
Confirmed incidents in which employees were dismissed or disciplined for corruptionNumber000
Confirmed incidents when contracts with business partners were terminated or not renewed because of violations related to corruptionNumber000
Public legal cases regarding corruption against the organisation or its employees during the reporting period Number000
Number of companies or individuals on Scatec projects subject to IFC investigation or sanctioning Number000

GRI 307-1

Non-compliance with environmental laws and regulations

There were no incidents of non- compliance with environmental, social or economic laws and regulations that resulted in significant fines or non-monetary sanctions in 2021.

GRI 419-1

Non-compliance with laws and regulations in the social and economic area

There were no incidents of non- compliance with environmental, social or economic laws and regulations that resulted in significant fines or non-monetary sanctions in 2021.

GRI 415-1

Political contributions

Scatec does not make donations or contributions to political parties, candidates, labour unions or trade associations.

The Transparency International Corruption Perceptions Index 2021

Extreme risk (0-19)High risk (20-39)High-medium risk (40-59)Medium risk (60-79)Low risk (80-100)
Honduras (23)South Africa (44)Norway (84)
Bangladesh (26)Tunisia (44)
Mozambique (26)Malaysia (48)
Uganda (27) Jordan (49)
Pakistan (28)Rwanda (53)
Mali (29)Czech Republic (54)
Laos (30)
Ukraine (32)
Egypt (33)
Philippines (33)
Argentina (38)
Brazil (38)
Lesotho (38)
Vietnam (39)

Accounting Policy

Scatec reports on key metrics related to ethics, compliance and anti-corruption. Key definitions:

  • Corruption: Corruption occurs when a payment, gift, favour, or advantage is offered, made, accepted or requested to influence a business decision, or in connection with someone’s position, office or assignment. Corruption may involve Public Officials, companies, or private individuals, and may occur directly or indirectly through third parties such as developers, service providers and joint venture partners.
  • Corruption incidents: The number of confirmed incidents of corruption received via Scatec’s publicly available whistleblower function (on our corporate website) managed by an independent third party.
  • Public official: A person who is elected or appointed government official or representative, an employee or representative of a state-owned or state-controlled company, an employee or representative for a company performing a governmental function, an employee of international public organisations (UN, EU, World Bank), a representative for a political party or a labour union, members of royal families, or close family members to any of the above.

Reports

Report from the Board of Directors