Ethics, Compliance and Control (ECK)

ALTEO launched its compliance programme and established the Compliance Manager function in 2015. In January 2016 it issued its Code of Ethics and adopted its Compliance Policy; both documents are reviewed annually. The Compliance Committee was also founded in 2016. As a result of the group’s dynamic growth, the Ethics, Compliance and Control organisation was established in January 2022.

In establishing the Company’s regulatory framework, the goal was to ensure transparent operation. Accordingly, we defined the framework of our business activities, we document our processes and we have set out the terms of cooperation between business areas, clearly defining tasks and the associated responsibilities.

The Compliance Management System is designed to ensure that corporate operations across the entire group comply with legislation, internal rules and the group’s Code of Ethics.

The Compliance Management System fundamentally acts as an operations-supporting, preventive and control function, ensuring the prevention of damage and abuse and the minimisation of risks across the entire scope of corporate operations.

At the ALTEO Group we always strive to do better. As a thinking, forward-looking organisation, we believe that by operating in line with our values and building on our credibility and our partners’ trust, we can be successful over the long term. We are committed to operating with integrity and responsibility and to fully meeting the high ethical standards we set for ourselves. With our Code of Ethics we wish to reaffirm this commitment to our employees and business partners.

To protect its data and information, the Company has defined its information and cyber security requirements, taking into account business expectations, the relevant legislation and professional recommendations. We expect our business partners to accept and comply with our internal information security rules.

In our business relationships we strive to take every measure to protect our data and business information in line with industry expectations.

To ensure the protection of data, information, IT systems and sites, the Company continuously protects and develops its systems.

Each year, in accordance with sectoral legislation, the Company certifies the closed nature of its billing system.

The IT and information security requirements concerning the closed nature of the billing system extend to the administrative, physical and logical protection requirements assigned to the security class of the electronic information system.

The Company has developed its internal data protection procedure based on Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – GDPR).

The Company processes personal data solely in accordance with data protection rules, for specified purposes and with an appropriate legal basis. It continuously raises employees’ data protection awareness through training and provides regular information on both existing and new data processing activities.

The Company’s data protection organisation provides ongoing support and advice to ensure that the company’s data processing complies with the GDPR.

The ALTEO Group operates a physical security system to protect the infrastructure of its facilities. We have established security categories, and every existing and newly added site is classified into a security category according to its characteristics, with the corresponding physical security system put in place.

The Company performs compliance risk management in order to identify, assess, manage and prevent compliance-related risks.

The ALTEO Group’s aim is to make the right decisions in the course of its business activities, to be aware of the risks that may arise, to develop plans for managing and preventing them, and to ensure operation in compliance with the law.

In the course of compliance risk management, the organisation systematically and methodically evaluates and develops the audited organisation’s:

Every manager and employee of the group must comply with the Compliance Policy, which we check regularly. During checks, every manager must make available all data, information and documents within the limits set by privacy and data protection legislation.

Risks identified during investigations are recorded together with the measures proposed to eliminate or mitigate them; the handling of the issues identified is regularly re-measured and analysed annually. We prepare a summary report on the latter for the Compliance Committee and the Supervisory Board. Since 2017 the annual compliance report has been published in our Sustainability and, later, Integrated reports. To prevent potential abuse and raise awareness, we regularly hold targeted training sessions.

Each year the Company’s senior employees assess the company’s compliance risks in relation to procurement, accounting, human resources, publicity and corporate management. To eliminate any risks identified, we develop an internal audit plan and internal communication.

We firmly reject all forms of corruption and bribery, which constitute particularly serious ethical offences in relation to government contacts, our suppliers and our business partners. We apply zero tolerance in every case involving bribery or corruption.

We do not enter into business relationships with suppliers who do not meet the company’s pre-qualification requirements. We expect our business partners to familiarise themselves with, accept and comply with our Code of Ethics.

We operate a whistleblowing hotline for reporting corruption and fraud, and reports can also be made by e-mail or telephone. We also give whistleblowers the option of anonymity.

We investigate every suspicion of corruption or fraud in accordance with our internal procedures. The ALTEO Group firmly upholds the principle that those who report suspected corruption or fraud must not suffer any retaliation or disadvantage, even if their good-faith report does not lead to the discovery of any illegality or misconduct.

Based on Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law, ALTEO Nyrt. provides internal and external reporting channels.

Reports can also be made anonymously via the online reporting system or by e-mail, which is available 365 days a year, 7 days a week, 24 hours a day. If an investigation has begun but is not completed within two months, the reporter and the person concerned are notified by e-mail of the expected completion date of the investigation.

Whistleblowers must not suffer any retaliation or disadvantage, even if their good-faith report does not lead to the discovery of any illegality or misconduct.