Business conduct

KPO Business Principles

KPO conducts its business based on KPO Business Principles introduced in 2019.

Our Business Principles govern how we conduct our business and set high standards of performance and ethical behaviour. We also expect all of our stakeholders, including contractors and suppliers, to respect and adhere to these Business Principles.

The full KPO Business Principles and a short video are available on our website.

Code of Conduct

The KPO Compliance Framework regulates and provides guidance on all aspects of compliance throughout the Company. Code of Conduct is the fundamental document, which establishes the core ethical principles, values and behaviours in the process of working inside and outside of the Company and when contacting with vendors, suppliers or other counterparties.

Our Code of Conduct is read in conjunction with our Business Principles and gives KPO staff more detailed guidance on how to apply Business Principles and the standards and behaviours required of our staff. It covers areas including international trade, health and safety, communications and gifts and hospitality. The copy of Code of Conduct is available on our website.

Fig. 7. KPO Business Principles

Awareness training on the Code of conduct and anti-corruption

KPO insists on creating a fair and equitable business environment where the ethical business principles in the KPO Code of Conduct are the foundation for all its relationships.

All new starters in KPO receive an introductory training course on the Code of Conduct. Besides, each KPO employee is required, on an annual basis, to make a Compliance Declaration acknowledging their familiarisation with their personal compliance obligations. The Code of Conduct and other ethical compliance policies and practical tests are available on the KPO intranet for each employee.

Due to the Covid-19 situation, the Compliance Department rapidly switched from face-to-face trainings to virtual trainings, successfully organizing several distance-training sessions for those KPO employees, who were supposed to be trained face-to-face.

Hotline and other compliance measures

To support the Company’s legal compliance programme, KPO has a toll-free, anonymous and confidential Hotline in place since 2012.

The Hotline provides an important tool for KPO’s employees, contractors and stakeholders to ensure a fair and safe working environment. The topics may include discrimination, sexual harassment, conflicts of interest, safety or environmental violations and/or improper financial practices or bribery. The caller can report on the alleged misconduct either by telephone or by completing an online report form. The report is then sent to the Compliance Department for review and to determine the appropriate actions. In some cases, employees can report concerns directly to the Legal Directorate.

In 2020, KPO Compliance Department received 102 new reports. All of the reports were duly considered and the appropriate actions taken. Most of the complaints related to workplace relation matters, whereby 93 complaints were addressed and closed in accordance with the KPO’s Compliance Investigation Procedure and/or Discipline Handling Procedure, depending on the nature of report.

The Compliance investigation team duly investigate the received reports and, in case the allegations are substantiated, consequence management actions are identified and carried out.
KPO has been currently implementing a new investigation procedure to enhance the management of the received reports and of the consequence management actions