Compliance policy

EPSO-G group's Compliance Management System is a set of internal policies, procedures and rules with external and internal requirements designed to protect interests of companies of the group and the group as a whole.

Compliance with internal and external requirements is a prerequisite for the implementation of EPSO-G group’s strategy and objectives in order to ensure a good business reputation of the companies of the Group.

EPSO-G  aims to implement an efficient compliance management system with the following purposes:

• to protect EPSO-G group companies from any  finance or  reputation losses that could result from the behaviour that fails to comply with internal and external requirements;
• to develop preconditions and measures to manage potential risks of noncompliance more efficiently in order to reduce their impact or case likelihood;
• to motivate EPSO-G group’s employees to work in accordance with the laid down requirements and to base their application on the values of EPSO-G group.

EPSO-G’s compliance management principles:

• The Three Lines Principle – The compliance management process is based on the “Three Lines Model”, where the participants of the first line (curators of certain fields) perform compliance implementation functions including the management of non-compliance risks, the participants of the second line (compliance officer) perform compliance coordination functions including the assessment of non-compliance risks, and the participants of the third line (internal audit unit) perform an independent audit of the activities of the first two lines.
• The principle of compliance with requirements – activities carried out must meet requirements not only in form but also in content that complies with the Group’s values.
• The principle of integrity – the compliance management process shall become a fundamental and integral part of daily operations of all Group companies, operating systematically in compliance with the provisions of the Group’s policies, processes and other internal documents.
• The principle of relevance and reliability of information – the compliance management is based on relevant data, monitoring, experience and expert evaluations.
• The principle of the risk-based approach application is to organise the compliance management process in such a manner that resources are allocated first to areas of the highest risk of non-compliance.
• The principle of transparency – information relating to the compliance management process, non-compliance risks and their causes is available without any obstacles to the participants of the compliance management process in accordance with their roles.
• The principle of good practice application – the compliance management process is guided by examples of the best practices identified and developed during the Group’s compliance management process.
• The principle of performance documentation and traceability – the compliance management process ensures that all key decisions and actions are properly documented, thus allowing for traceability and control of actions performed and improvement of the compliance management process.