Consistently enforcing a proactive stance to corruption in all its forms is of the outmost importance for a global operation such as ours. Every year, the internal audit department does a risk assessment of all of our operations according to Transparency Inter-national’s Corruption Perception Index as part of our internal audit review process. Our review, escalation process, and whistle-blower system all jointly showed that 2017 was a year with zero cases of confirmed corruption.

This is much due to our rigorous and forceful steering documents and actions to implement our zero tolerance to fraud and other unethical behavior. Key factors are our comprehensive policy base for combating corruption, including our Supplier Code of Business Conduct and Code of Business Conduct for employees.  We also have a whistle blower policy in place that applies to Transcom employees, agency workers, contractors, and home agents. We offer employees to file their complaints via email, mail, or fill out a form (where they can be anonymous) via our intranet.

All complaints and malpractices are thoroughly investigated through a fair, quick and confidential assessment process. The length and scope of the investigation will depend on the subject matter of the concern. Where relevant, the investigation can escalate to the Chairman of Transcom’s Board of Audit Committee, an independent auditor, or the police or other law enforcement authority. The employee will be informed of the commitments Transcom has taken after the complaint, unless the circumstances do not permit to. If urgent action is required, this may be taken before any investigation is conducted. The overriding principle is the interest of the Company and its stakeholders. The employee will, unless circumstances do not permit it, be told what action Transcom has decided to take and must treat any such information with the strictest confidence.

We further train all employees at the start of their employment in anti-corruption as part of the mandatory Code of Business Conduct training. All employees must after completion also provide a signed affidavit of their understanding of the Code of Business Conduct. In the operations we ensure that all risks of corruption are addressed in each country through the countries risk register, in the scope of our internal audits and in strategic risk assessments for business developments.



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