STRATEGIC REPORT
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SUSTAINABLE DEVELOPMENT
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COMPLIANCE AND BUSINESS ETHICS
122
X5’s Inside Information and Dealing Code aims to ensure that X5
employees do not abuse, and do not place themselves under suspicion
of abusing, inside information and that they comply with their obligations
under the applicable rules on inside information and securities trading.
As an industry leader, we are aware of our responsibility to the
government, society, our shareholders and business partners, and we
aim to fully comply with legal and ethical standards, as well as best
corporate practices, in order to serve as an example for other market
participants.
The Code of Interaction with Business Partners contains provisions
regarding compliance with trade and competition laws, anti-corruption
and anti-fraud legislation, legislation on the quality of products and
services, and legislation on environmental protection and occupational
health and safety, communication standards, information protection,
prevention of conflicts of interest, etc. Violations of the Code of
Interaction with Business Partners are handled by X5’s Conciliation
Commission.
COMPLIANCE
POLICY
POLICY ON COUNTERING
MISCONDUCT INCLUDING
FRAUD AND CORRUPTION
INSIDE INFORMATION
AND DEALING CODE
CODE OF INTERACTION
WITH BUSINESS PARTNERS
In order to ensure compliance with the requirements of regulators and
stakeholders, as well as internal standards and rules on business
conduct and ethics, X5 has adopted a Compliance Policy in accordance
with ISO standards on GRC and management systems.
Compliance risks are assessed and reviewed by the Audit and Risk
Committee on an ongoing basis.
X5 and its divisions are committed to conducting business in an
ethically responsible manner and complying with all applicable laws and
regulations relating to anti-corruption and bribery.
In addition to the Code of Business Conduct and Ethics, X5’s Policy
on Countering Misconduct Including Fraud and Corruption (the
“Anti-Corruption Policy”) prohibits any form of corruption or bribery,
including facilitation payments. It aims to create a culture of honesty and
zero tolerance for illegal behaviour among staff, and also to eliminate any
risks of involving the Company in corrupt activities. Our anti-corruption
system includes a set of mechanisms, procedures and tools aimed at
preventing, uncovering, investigating and responding to all possible
cases of misconduct. Furthermore, it establishes roles and
responsibilities for departments and management bodies within the
anti-corruption system. Our aim is to conduct business only with those
partners that share X5’s principles of zero tolerance for corruption and
fraud, and relevant provisions are included in the agreements with our
suppliers and other business partners.
Policy highlights