CEZ Group’s Anti-bribery Policy
CEZ Group applies a system of preventive, detection, and reaction measures across its corporate processes against both passive (accepting a bribe) and active (giving a bribe) corruption, as well as indirect bribery.
CEZ Group has formally implemented a corruption prevention policy, which is part of the CEZ Group Compliance Management System Policy. The agenda of corruption prevention is centrally managed and supported by the Corporate Compliance Committee. The assessment of corruption risks is carried out regularly every year as part of the process defined in the Corporate Compliance Directive, including risk identification, impact and likelihood scoring, and mitigation planning. Furthermore, CEZ Group has implemented an Anti-Bribery Program, issued specifically for the CEZ Group environment, which regulates all anti-corruption processes within the framework of the strict requirements of ISO 37001:2016 – Anti-Bribery Management Systems (ISO 37001).
Since 2021, a certified anti-bribery management system (ABMS) pursuant to ISO 37001 has been implemented in the Procurement Department and for related processes performed by the Audit and Compliance Department of ČEZ, a. s. This certification completes our long-standing effort to build a strong compliance system, which is based on the principle of zero tolerance for corruption. This internationally recognized certificate 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 conduct by employees and managers. ČEZ, a. s., was the first energy company in Central Europe to obtain this certification. In September 2024, ČEZ, a. s., was recertified by TÜV SÜD Slovakia s.r.o. In 2024, the certification was also granted to the Procurement Coordination Department of ČEZ Distribuce, a. s., and in 2025, both of these entities successfully completed supervisory certification audits by TÜV SÜD Slovakia s.r.o.
The company thus has a comprehensive system of corruption risk controls in place. Key control mechanisms include: the four-eyes principle, transparent SAP approval workflow, third-party due diligence (supplier integrity), conflict of interest checks, separation of roles in purchasing and payment approval, setting approval levels according to transaction value (signature code), the Whistleblowing Hotline, gift checks, regular training of employees in risk-exposed positions, and verification of selected information provided by new employees / job applicants (background check). These control mechanisms are reviewed by an internal audit.
Third-party due diligence (screening suppliers before entering into a contractual relationship or screening a business entity before a potential acquisition of a company) is a mandatory part of the procurement, acquisition, divestment, and other potentially risky business transactions. The procedures are detailed in the managing documentation Third Party Verification.
In order to effectively minimize the risk of misuse of the otherwise acceptable practice of accepting and providing gifts, CEZ Group applies an approach based on limiting gifts through its internal rules, emphasizing the exceptional nature of their use. In order to create an adequate mechanism for ensuring the acceptability of received and provided gifts, financial limits have been set, which set out the obligation to report, approve, and record gifts, or possibly refuse them (unacceptable gifts are also defined).
The effectiveness of the implemented actions and control mechanisms is verified as part of compliance checks and internal audits, which analyze possibly fraudulent scenarios (regular audits of ethical standards).
In case of violation of the ABMS rules, an internal investigation is initiated, the result of which may include the imposition of actions depending on the specific circumstances of the case, including possible employment-related sanctions.
Internal investigations are conducted by the relevant persons from the Compliance Audits and Controls Department. These persons operate independently 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 twice a year about investigations conducted, their results, and the corrective actions taken. The reporting process also includes information about investigations into possible corruption and bribery. External and internal supervisory audits have repeatedly confirmed that the ABMS measures in place are effective.
The same applies to the risk of fraudulent activity: there is a comprehensive set of of actions against individual types of fraud in place, which is also internally audited. Internal audits assess the level of risk and the setting and effectiveness of actions in the Audit Report.
In 2025, there were no confirmed cases of violations in the areas of anti-money laundering (AML), bribery, or corruption. No cases of conflict of interest or incidents related discrimination or harassment were recorded.
| 2025 | |
|---|---|
| Number of members of governance body who have completed Code of Conduct training | 489 |
| Number of managers who have completed Code of Conduct training | 4,066 |
| Number of other employees who have completed Code of Conduct training | 27,810 |
| Total (sum of managers and other employees) | 31,876 |