CEZ Group’s Anti-bribery Policy

Since 2021, a certified anti-bribery management system has been implemented in the Procurement department and on related processes performed by the Audit and Compliance department of ČEZ, a. s., in accordance with ISO 37001:2016 – Anti-bribery management systems. This certification finalizes CEZ Group‘s long-standing effort to build a strong compliance system on the principle of zero tolerance for corruption. The internationally recognized certification also provides a guarantee to all stakeholders that measures are constantly being taken to comply with legal and ethical conduct in order to minimize the risks of unfair behavior by employees and managers. ČEZ, a. s., was the first energy company in Central Europe to receive this certification. ČEZ, a. s., received recertification by TÜV SÜD Czech in September 2024. In 2024, the certification was newly awarded to the Procurement Coordination department of ČEZ Distribuce.

Preventive measures applied in relevant processes include financial and non-financial controls, such as the four-eyes principle, separation of roles and responsibilities, and setting approval levels based on the value of the transaction. Other preventive measures include verifying selected information provided by a new employee/job applicant (background check prior to starting employment). Suppliers due diligence (screening suppliers before entering into a contractual relationship, screening a business entity before the potential acquisition of a company) is a mandatory part of the procurement process, acquisitions and divestitures, or other potentially risky business cases.

In order to effectively minimize the risk of accepting and providing gifts for corrupt purposes, CEZ Group applies, through its internal rules, an approach based on limiting the value of gifts, emphasizing the exceptional nature of the use of this means. In order to create an adequate mechanism for ensuring the acceptability of received and provided gifts, financial limits have been set, imposing the obligation to report, approve, and record gifts, or to refuse them (unacceptable gifts are also defined).

In case of a violation of the rules of the anti-bribery management system (ABMS), an internal investigation is initiated, the result of which may include the imposition of one of the measures depending on the specific circumstances of the case, including possible employment-related sanctions. The effectiveness of these measures is regularly verified as part of compliance checks and internal audits, which analyze possible fraudulent scenarios.

Internal investigations are conducted by relevant persons from the Internal Investigations and Checks department and Compliance Audits and Controls department. These persons are separated from those who are dedicated to the prevention of corruption and bribery (CMS and AI department). Final reports on the results of the investigation are always submitted to the management of the company concerned by the investigation. The Board of Directors of ČEZ, a. s., is informed about investigations, their results, and the corrective measures taken twice a year. This reporting also includes information about investigations into possible corruption and bribery.

External and internal supervisory audits have repeatedly confirmed that ABMS measures are effective. The same applies to the risk of fraudulent activity: a number of measures against individual types of fraud are in place, which are audited as part of individual internal audits. Internal audits assess the level of this risk and the setting and effectiveness of measures in the audit report. No confirmed case of bribery or corruption was registered in CEZ Group in 2024.

• Commitment to Ethical Conduct
• Anti-corruption certificate