The renewables industry is built by people who believe in a better future. However, many of the countries where we operate are vulnerable to corruption which makes our work challenging. We make extensive efforts in our projects and operations to prevent corruption and other unethical practices.
Scatec is opposed all forms of corruption and strives to meet the highest ethical standards across our business activities. Our Code of Conduct prohibits all forms of corruption, and we implement internal controls to prevent, detect and remedy improper conduct through our and Anti-Corruption Compliance Programme. Our approach is risk-based, and we keep a special focus on markets and activities particularly exposed to corruption.
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GRI 205-1: Operations assessed for risks related to corruption
Corruption risk assessments form the basis for selecting the areas that requires specific mitigating actions and resource allocation. Each business unit is required to regularly assess and prioritise corruption risks in their activities. The Global Compliance Officer supports the business unit in their risk assessments and in identifying mitigating measures.
We conduct corruption risk assessments at country, project and contract level. Scatec utilises the assessments to pinpoint areas which require specific attention, mitigating action and resource allocation. When risk is identified, it is recorded and reported to the relevant stakeholders in each project to ensure awareness and implementation. In addition, we conduct a group risk assessment for every business unit each year.
Projects moving from opportunity, development, and structuring to the delivery and power-production phases are assessed through Decision Gates. There are four Decisions Gates with clear criteria and requirements related to screening, compliance and risks of corruption.
Contracting Parties such as business partners, suppliers and corporate customers may expose Scatec to reputational, legal, and operational risk. Scatec is committed to taking the necessary steps to manage the risks arising from third-party relationships. As part of this commitment, no relationship with a third party may be established without appropriate integrity due diligence (IDD) of the business relationship, and no contract shall be entered into without adequate anti-corruption undertakings. All third party relationships shall undergo sufficient monitoring.
All new third parties, hereunder business partners, suppliers and corporate customers must undergo appropriate IDD in accordance with the Integrity Due Diligence Procedure. The IDD requirements for third parties are risk-based and determined by the risk of the country, the scope of work and the annual value of the contract. The relevant Project Manager from Business Development or Solutions is responsible to ensure that the Integrity Due Diligence Procedure is complied with.
Local development partners and consultants assist in development activities, which often includes interactions with Public Officials and government authorities. These business relationships represent a high risk to Scatec, and is therefore placed under specific control measures: Enhanced IDD requirements, tailored Anti-Corruption clauses, and enhanced monitoring activities.
GRI 205-2: Participation in anti-corruption training and targeted workshops for high-risk groups
Scatec requires all employees to complete training in our anti-corruption policies. We have developed an advanced gamified Code of Conduct training, which is an interactive game consisting of dilemma training and mini games. The course introduces the Code of Conduct and the main procedures adopted to prevent and detect corruption. Employees require an 80% pass rate for each module to be certified on the training platform. The objective of the training is to ensure that Scatec’s employees are familiar with applicable anticorruption laws and are prepared to identify and manage the corruption risks they may encounter while working for Scatec.
All Scatec employees are required to attend the in-person anti-corruption training course every three years. The Global Compliance Officer is responsible for coordinating the anti-corruption training. For employees located on project sites during construction, it is often necessary to coordinate training in the language commonly used on site. The Global Compliance Officer is responsible to ensure that anti-corruption training is made available in the appropriate language and that the trainer is equipped to provide guidance on anti-corruption laws and the relevant governing documents.
Employees with high exposure to corruption are required to attend tailored anti-corruption training. An analysis is performed every year to determine employees with specific exposure to corruption risk owning to their particular role. Based on these assessments, Scatec has developed specialised workshops for employees working within the departments of Business Development and Solutions. Each business unit is responsible for identifying the Scatec employees with specific training needs, supported by the Global Compliance Officer. The HR function shall support the Global Compliance Officer to effectively deliver training in the locations outside HQ.
The number and percentage of employees that the organisation’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region, is presented in the tables below:
| Europe | Africa | LATAM | MENA | Asia | Total | % | |
|---|---|---|---|---|---|---|---|
| Permanent employment | 255 | 242 | 92 | 106 | 83 | 778 | 100% |
| Temporary employment | 8 | 75 | 40 | 1 | 22 | 146 | 100% |
| 924 | 100% |
The number and percentage of in-scope employees that have received training on anti-corruption, is a total of 701 employees, of which 100% completed the training in 2022.
Scatec’s anti-corruption policies and procedures are communicated to all suppliers and business partner globally. Contracting Parties such as business partners, suppliers and corporate customers may expose Scatec to reputational, legal, and operational risk. No relationship with a third party may be established without appropriate integrity due diligence (IDD) of the business relationship, and no contract shall be entered into without adequate anti-corruption undertakings. All third party relationships shall undergo sufficient monitoring.
All new third parties, hereunder business partners, suppliers and corporate customers must undergo appropriate IDD in accordance with the Integrity Due Diligence Procedure. The IDD requirements for third parties are risk-based and determined by the risk of the country, the scope of work and the annual value of the contract. The relevant Project Manager from Business Development or Solutions is responsible to ensure that the Integrity Due Diligence Procedure is complied with. Detailed guidance of the Integrity Due Diligence process is described in the Integrity Due Diligence Procedure.
All suppliers must sign our Supplier Code of Conduct and confirm conformance with the IFC’s anti-corruption guidelines which we integrate into all our contracts, in addition to HSSE, environmental, social, and quality assurance and control requirements. In 2022, 100% of Scatec’s new business partners and contracted suppliers received our Code of Conduct and Partner Conduct Principles.
GRI 205-3: Confirmed incidents of corruption and actions taken
GRI 406-1: Incidents of discrimination and corrective actions taken
he whistleblower function is available to all employees, suppliers, partners and customers of the company through internal channels and our corporate website. The function is operated by an independent third party and available in eight languages. All whistleblowers have the option to be anonymous.
Number of reports received in 2022: 8
The reports alleged breaches of various issues including conflict of interest, discrimination, misconduct in the workplace environment, and alleged fraud and corruption. Enquiries were investigated regarding all allegations. No allegations of corruption or discrimination were substantiated and corrective and/or disciplinary actions were implemented accordingly by Management.
| Key performance indicator | Unit | Target 2022 | Actual 2022 | Actual 2021 | Actual 2020 | Target 2023 |
|---|---|---|---|---|---|---|
| Confirmed incidents of corruption and actions taken | ||||||
| Confirmed incidents of corruption | Number | 0 | 0 | 0 | 0 | 0 |
| Confirmed incidents in which employees were dismissed or disciplined for corruption | Number | 0 | 0 | 0 | 0 | 0 |
| Confirmed incidents when contracts with business partners were terminated or not renewed because of violations related to corruption | Number | 0 | 0 | 0 | 0 | 0 |
| Public legal cases regarding corruption against the organisation or its employees during the reporting period | Number | 0 | 0 | 0 | 0 | 0 |
| Number of companies or individuals on Scatec projects subject to IFC investigation or sanctioning | Number | 0 | 0 | 0 | 0 | 0 |
GRI 415-1: Political contributions
Scatec does not make donations or contributions to political parties, candidates, labour unions or trade associations.
GRI 2-27: Compliance with laws and regulations
Scatec is committed to conducting our business in a sustainable manner and in accordance with leading, global Environmental, Social and Governance (ESG) principles. In addition, we are strongly positioned to implement best practices of Environmental, Social and Corporate Governance (ESG) management approaches.
International best practice frameworks and guidelines
We strive to work in line with the Equator Principles and IFC Performance Standards in all operations and our work is guided by the Organisation for Economic Co-operation and Development’s (OECD) Guidelines for Multinational Enterprises, the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, and the core conventions of the International Labour Organization (ILO).
Regulations and compliance
As a listed company on the Oslo Stock Exchange in Norway, we comply with the Norwegian Diversity Act, Norwegian Transparency Act and EU Taxonomy on environmentally sustainable activities. In 2023, we will assess our Corporate Sustainability Reporting Directive (CSRD) readiness and aim to close any gaps identified towards compliance and best practice.
The compliance function, led by the Chief Compliance Officer, has overall responsibility for building and monitoring compliance within Scatec. This responsibility includes providing guidance on compliance matters and following up potential violations of our governing framework by our employees, partners and suppliers. Where required, a local compliance officer will be appointed.
Anyone who violates Scatec’s Code of Conduct may face disciplinary sanctions which can include termination of employment and the involvement of relevant authorities. Everyone working in Scatec is subject to the same consequences and will be subject to sanctions, regardless of their position or seniority. Leaders who passively tolerate violations by their team members may also face disciplinary actions.
Compliance with applicable laws and regulations are mandatory in all Scatec activities, but business ethics extend beyond simple compliance. Scatec conducts business with integrity, respecting the cultures, dignity and rights of individuals in all the regions where we operate. We strive to conduct business in a way that makes our employees proud to work for Scatec. In 2022, no significant fines were paid nor were non-monetary sanctions in place against Scatec.
