Crime Prevention DPP (Compliance Programme)

Prague Transit Company (hereinafter referred to as "DPP") has long been committed to zero tolerance for faulty and corrupt behaviour in any form.

The established Anti-Corruption Rules already contain an unequivocal declaration of effective prevention and combating of corrupt behaviour.

In addition, The Code of Ethics has been established, which contains a set of rules of conduct that provide guidance for every employee, member of the authorities and any other responsible person in making decisions and accepting legal and moral responsibility for their actions.

In addition to these basic documents, a set of other internal standards and processes have been developed to specify the duties and responsibilities in the area of crime prevention at DPP. These reflect the requirements of the Law on the Criminal Liability of Legal Persons and the Law on the Responsibility for Offences and Proceedings thereon and have been issued within DPP under the title DP Crime Prevention Programme and The Risks Arising Therefrom.

In connection with the intensification of activities in this area, the DPP management decided to introduce the international standards ISO 37001 (anti-corruption management system) and ISO 37301 (compliance management system) within DPP in order to strengthen the effective prevention and response to misconduct, including violations of established rules, corrupt practices, or unethical behaviour (so-called Compliance).

DPP holds certificates of the Compliance Management System (CMS) and Anti-Corruption Management System (ABMS) according to internationally recognised standards ISO 37301 and ISO 37001

In December 2022, DPP obtained the certificate of the anti-corruption management system according to the recognised international standard ISO 37001 and in December 2023 the certificate of the compliance management system according to ISO 37301. This is the result of a process of setting up new anti-corruption and other preventive measures at DPP, which included, for example, an analysis of corruption and compliance risks, the introduction of a number of new rules or fully functional reporting channels. Annual surveillance audits by the certification authority are now underway to maintain both certificates.

DPP Press Release - DPP has successfully passed a comprehensive audit and obtained a certificate of the anti-corruption management system according to the international standard ISO 37001.

The following activities and changes are currently being implemented in DPP to successfully incorporate the ISO standards:

Creation of an independent Compliance function (Unit 900320, Compliance Department) with a mandate from DPP management to oversee the design and implementation of all Compliance activities and the anti-corruption management system, responsible for their overall functionality;
A comprehensive approach and a serious commitment by DPP to actively and permanently participate in the prevention of misconduct, corrupt and unethical behaviour, and thus contribute to the improvement of a corporate culture based on internal integrity and personal responsibility of employees, DPP representatives and other persons;
Ongoing communication of compliance and corruption prevention issues to employees, business partners and the public;
Full support and protection for anyone who refuses to participate in or makes a good faith report of misconduct, corrupt or unethical conduct (including persons close to the whistleblower),
Building a functional system of internal controls, mechanisms and processes that create an effective defence of DPP against misconduct, corrupt or even unethical behaviour of employees and other responsible persons as well as business partners (e.g. increasing transparency of certain processes, managing compliance and corruption risks, financial and non-financial controls, screening of designated groups of employees and business partners, gifts, hospitality and sponsorship, prevention of conflicts of interest, etc.);
Anchoring certain new roles, responsibilities and obligations in the anti-corruption and compliance area and inside and outside DPP;
Updating certain existing and adopting new internal standards, including the DP Anti-Corruption Programme, which sets out rules for the prevention, detection and thorough investigation of any corrupt behaviour, binding to all employees and other responsible persons and also applicable to business partners.

Glossary of terms

Compliance is a general term for conformity with the rules set by legal or internal norms as well as ethical rules or generally rules of decent behaviour, on the part of all stakeholders, i.e. the business company itself, its employees, management and business partners.

Compliance has its origins in good corporate governance, which should be an integral and natural part of internal strategy and the right corporate culture for any business.

Misconduct is an act in violation of applicable laws, internal norms or breach of ethical standards committed by DPP, employees, other responsible persons and third parties in connection with DPP's activities that could lead to criminal, misdemeanour or other administrative liability of DPP or otherwise damage the reputation of DPP.

Corrupt conduct is the direct or indirect giving, offering, promising, mediating or, conversely, demanding or accepting an unjustified material advantage (bribe), as well as abuse of position or conflict of interest.

A bribe is any unauthorised benefit (a tangible or intangible item or other form of compensation) that results in direct financial gain or another form of advantage received or intended to be received by the bribed person or, with their consent, another person who is not entitled to it. A bribe may typically include, for example:

money or valuables,
any other tangible or intangible property,
procuring discounts or direct payment for holidays, experiences or services,
appointment to an office or position or other non-pecuniary benefit, consideration or advantage,

not only for the bribed person, but also, for example, for persons close to them, all in a causal connection between the bribe and the consideration (i.e. in a situation where one fact gives rise to the other fact). At the same time, there is always an intention to bind the bribed person in a non-standard way.

Conflict of interest refers to a wide range of situations in which personal interests interfere with the ability to make objective and impartial decisions about the best interests of the employer or a third party, and, conversely, self-interests may be exercised to their detriment.

Conflicts of interest typically arise in situations where an employee is in a position in which they:

may gain financial benefit or avoid financial loss to the detriment of the employer or a third party;
have a different interest from that of the third party in the outcome of the service provided to it or in the outcome of a transaction carried out on behalf of the third party;
have an incentive to put the interest of a particular third party ahead of the interest of another third party,

and are also engaged in business or other gainful activity in the same field as the employer or third party.