There is intense competition in the construction sector. Implenia engages in this competition by fair means and has a zero-tolerance policy towards anti-competitive behaviour. The company adheres strictly to all applicable national and international antitrust and competition law, and it condemns any form of bribery and corruption.
Implenia checks each project to ensure that internal and external requirements for fair competition are met. The company has introduced a mechanism to counter corruption based on the “two-pairs-of-eyes” principle. Auditors also regularly check the books for anything suspicious as part of the regular audit process.
Implenia has signed off Group-wide competition regulations to help make employees more familiar with competition law and protect them from infringements. The instructions are unequivocal. For example, the internal regulations make it clear that oral and non-binding arrangements can still violate competition law, and they tell employees how to conduct themselves correctly.
Group integrity guidelines flesh out the principles of the Code of Conduct as they apply to corruption and bribery. They contain binding obligations for the prevention and active fight against corrupt practices and attempts at bribery. Implenia expects its employees to comply strictly with the law and guidelines. The integrity guidelines include concrete rules on accepting and offering personal gifts, for example. They set out country-specific financial thresholds, above which personal gifts either have to be approved or are forbidden.
Implenia doesn’t just discuss compliance issues with its employees when they first join the company. Workers are invited to compliance training sessions regularly throughout their career at the company. Participation in this training, which helps keep the main principles fresh in employees’ minds, is monitored. In this way, Implenia ensures that its people have a deeper awareness and understanding of the topic.
In order to sensitise its workforce to important compliance issues, Implenia brings these up regularly and links them to ongoing processes. “Impact”, the staff magazine also regularly features fictional but realistic everyday situations to highlight where permissible business practices end and illegal behaviour, such as bribery or corruption, begins. Finally, pocket cards on specific topics – rules for meetings for example – are distributed to staff.