Every year, all Company employees must take and pass a mandatory online course to confirm their knowledge of our Code of Business Ethics. We have begun updating the Code to comply with our HEART values. The amended Code will serve as a general guide for employees in situations that may arise in their day-to-day activities.
Management of conflicts of interest
With respect to conflicts of interest, we are guided by our Charter, Corporate Governance Code and Code of Business Ethics.
Every year, all directors must submit a letter confirming that they do not have any conflicts of interest. In case of a potential conflict of interests, the Directors involved must inform the Board and management immediately. No conflict of interest was registered in 2017.
In 2017, we started designing a new compliance function. So far, drafts of the following policies have been developed: Anti-corruption Policy, Conflicts of Interest Policy and a Whistleblowing Policy, which are planned to be approved and implemented in 2018. In addition to existing reporting channels arranged for employees, we are planning to establish an independent third-party operator to provide a telephone, e-mail and web-based reporting capability that would ensure the anonymity of whistle-blowers.
Corporate liability insurance
Since 2011, we have been purchasing Directors, officers and corporate liability insurance, which covers the obligations of our Company and its Directors and officers in accordance with applicable legislation to compensate for losses incurred by third parties as a result of wrongful acts committed during the performance of their official duties. Expenses incurred as a result of any claim brought against the Company and its Directors or officers in connection with the performance of their official duties are also covered.
According to the policy, a local insurance company covers 5% of the risk and reinsures 95% in a reputable international market through a reinsurance company with a rating of at least an A in accordance with Standard & Poor’s system or an equivalent rating on the part of other rating agencies. The insurance period is one year.