Respect, dignity and integrity underpin our conduct at all times. We are proactive and act in a responsible, honest and professional manner in all aspects of our day-to-day work. We abide by the rules and principles outlined in Slovenian Constitution, international agreements, applicable laws and other regulations and good business practice.
Our aim is to promote solidarity, be open-minded, support one another, share experience, foster respect for older generations, and encourage our younger colleagues. We know that our success and – by extension – our ability to accomplish the Group's mission are closely linked to how happy our employees, business partners and decision-makers are.
The Code of Conduct adopted in SŽ Group prescribes standards of professional conduct that must be adhered to by the Group's employees. The Code is produced in line with the Corporate Governance Code for Companies with Capital Assets of the State (Slovenian Sovereign Holding (SDH) 2020) and SDH's Code of Ethics (2020).
The Code regulates the professional conduct of our employees to promote a good public image of the Group and maintain the integrity of the profession while minimizing the risk of corruption and unlawful and unethical conduct.
a. Honesty and law abidance
We shall always act with integrity and in accordance with the high standards appropriate to and expected of a professional person while applying the values and principles set forth hereunder. We carry out our duties with care and diligence according to the statutory and regulatory provisions, the by-laws and the applicable legal practice.
b. Trust and respect
Through our work, we endeavour to invite trust and respect. Our conduct and professionality help maintain a good relationship with all company stakeholders. The results we produce showcase our work proficiency and efficiency.
c. Management integrity
Integrity is essential for managers, as they need to set an example for employees and motivate them to act with integrity at work.
We understand that the way our managers and leaders act serves as a model for others in the company, so we act in line with the expectations we hold vis-a-vis our colleagues and other stakeholders.
Integrity underpins our long-term success. Our business adheres to the applicable regulatory and statutory provisions and in-house guidelines and values, while situations not regulated in such manner serve as an opportunity to display the kind of qualities we expect from others: honesty, fairness and transparency.
Our managers bear the responsibility to uphold the principles of integrity in the company. They have the duty to underscore, at every opportunity, the importance of ethically sound behaviour and, in doing so, serve as an example to others. Every employee must act with integrity and in an ethically sound manner, follow the statutory and regulatory provisions, and uphold the company values.
d. Independence, impartiality and non-discrimination
We do our work independently, but also remain open to input provided by our stakeholders. Any legitimate concerns brought forward by our stakeholders are assessed in an impartial and non-discriminatory manner to make the best possible decision.
We do not abuse our position or avoid situations – whether in private or in public – which could compromise our impartiality or independence and have a negative impact on our own reputation or on the reputation of SŽ Group. Impartiality and independence are always at the heart of your work.
Integrity built on ethics, compliance and effective risk management.
Corporate compliance is comprised of a number of different policies and by-laws in regard to our duties and responsibilities to maintain business continuity and minimize the risk of regulatory breaches.
Compliance risk management
Compliance risk management is embedded in all our business processes and allows us to identify and manage potential risks which could disrupt achieving the strategic and business objectives at both company and Group level.
We uphold a no-tolerance policy towards all forms of fraud, misuse and unethical market practices.
Compliance with applicable rules is monitored by the Chief Compliance Officer, with an effective system put in place to any alleged contraventions of the Code.
Our guiding principle is to make decisions which benefit the companies in the Group and avoid situations which may result in a conflict of interest.
Under the Integrity and Prevention of Corruption Act (ZIntPK), SŽ Group has to produce and adopt an integrity plan, which serves as a record of risks faced by the Group. The plan focuses on exposure to breaches of ethics, identifies risk factors for corruption and other forms of unlawful and unethical conduct, and defines the measures to manage said risks.
The Commission for the Prevention of Corruption (PKP) produced a common integrity plan model to be applied in all state-owned businesses, which was first implemented in the Group in 2016.
In response to the changes in workplace environment, past experience, and new compliance regulations, the plan was revised in 2020.
The revision, which was adopted by the company’s Supervisory Board in May 2020, redefined risk groups and revised risk management measures, timelines and holders of authority together with a clear definition and separation between permanent and temporary measures.
The integrity plan contains corruption risks and integrity breaches as identified by the company. Risks in other business areas of the Group are recorded in the Risk Register, which forms – in conjunction with the integrity plan – a comprehensive list of identified risks and the associated risk management measures.
Pursuant to Article 55 of the Slovenian Sovereign Holding Act (ZSDH-1), the monitoring the implementation of the integrity plan is effected by the Chief Compliance Officer, who reports about their work to Slovenske železnice’s Supervisory Board.
The Compliance Officer
The Chief Compliance Officer (CCO) works in the Compliance and Risk Management department of the controlling company Slovenske železnice, d. o. o., and – in conjunction with the governing and control bodies – has the duty to:
- measure and manage regulatory risks,
- coordinate business processes,
- ensure that the company has an effective system of internal controls,
- promote awareness, organise training sessions and provide advice on how to improve business integrity,
- handle reports of alleged contraventions of the Code or of the applicable regulations, internal rules and ethical principles,
- make regular reports to the top management and control authorities.
The CCO monitors and reviews compliance procedures and makes sure that the Code of Conduct is adhered to.
The senior management of controlled companies in the Group and middle- and low-level managers in the controlling company work in liaison with the COO and have the duty to put in place appropriate compliance procedures in areas under their responsibility.