Case study: How ENEC promotes business ethics and integrity
ENEC (Emirates Nuclear Energy Corporation) was established by decree in December 2009 by the President of the United Arab Emirates (UAE) to implement a peaceful nuclear energy programme in the UAE in order to address the country’s growing demand for electricity, while reducing its carbon footprint and diversifying its energy portfolio. ENEC requires all employees, contractors, business partners and representatives to act in accordance with the highest standards of personal and professional integrity Tweet This! in all aspects of their activities, and to comply with all applicable laws, rules, regulations, and ENEC standards, policies and procedures.
This case study is based on the 2019 Sustainability Report by ENEC published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
ENEC has established and implements a robust set of standards, principles and model behaviours, with the goal of creating and sustaining a corporate environment in which the affairs of ENEC and its subsidiaries are conducted in a fair and transparent manner, free from any acts of fraud or misconduct. In order to promote business ethics and integrity ENEC took action to:
- implement a Code of General Business Principles and Ethics
- establish an Anti-Fraud and Misconduct Programme
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With this case study you will see:
- Which are the most important impacts (material issues) ENEC has identified;
- How ENEC proceeded with stakeholder engagement, and
- What actions were taken by ENEC to promote business ethics and integrity
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What are the material issues the company has identified?
In its 2019 Sustainability Report ENEC identified a range of material issues, such as health and safety of employees, contractors, and community, environment management & compliance, emergency preparedness, operational efficiency, waste management. Among these, promoting business ethics and integrity stands out as a key material issue for ENEC.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups ENEC engages with:
To identify and prioritise material topics ENEC engaged with its stakeholders through the following channels:
| Stakeholder Group | Method of engagement |
| Government Entities
| · Site delegations, facility tours and inspections · Regular meetings and written correspondence · Programme Executive Update · Participation in governmental initiatives and campaigns |
| Nuclear-Specific Organisations
| · Regular meetings and workshops · Regular reports and programme updates · Delegations to site · Shared initiatives · Knowledge-sharing workshops · Interactive dialogue · Reporting · International Advisory Board · Associated events, seminars, conferences and regional events |
| Media
| · Arranging interviews · Site visits · Media training |
| International Organisations, Government and Financial Institutions | · Delegations and events · Responding to on-going requests for information
|
| Academic Agents
| · Energy Pioneers Programmes · Regular events and career fairs at schools and universities |
| Prime Contractor Programme Related Companies
| · Regular meetings and workshops · Regular reports and programme updates · Knowledge-sharing · Interactive dialogue · Reporting · Associated events, seminars, conferences and events |
| Social Actors
| · Awareness sessions · Internal engagement programmes · CSR activities |
| Administration, Infrastructure & Utility Organisations
| · Meetings · Benchmarking · Non-Objection Certificate · Regular meetings and workshops · Regular reports and programme updates |
What actions were taken by ENEC to promote business ethics and integrity?
In its 2019 Sustainability Report ENEC reports that it took the following actions for promoting business ethics and integrity:
- Implementing a Code of General Business Principles and Ethics
- The ENEC Code of General Business Principles and Ethics, updated in 2019, frames the ethical and legal practices that ENEC requires all employees and contractors to uphold. The Code covers a wide range of topics including fraud, anti-corruption, and misconduct. All staff are required to read and acknowledge The Code on an annual basis, and it is a mandatory reading for all new hires. Throughout the year, compliance and anti-fraud training and awareness sessions are provided to employees with the support of senior management. These sessions continue monthly, across all functions. ENEC has a zero-tolerance approach to all forms of fraud or misconduct. No incidents of bribery or corruption were detected or reported in 2019. Also, in 2019 ENEC launched two compliance and ethics campaigns, using quizzes, posters, and newsletters. The campaigns covered topics regarding anti-bribery, code of ethics awareness, conflict of interest, retaliation, fraud, respecting others, and harassment.
- Establishing an Anti-Fraud and Misconduct Programme
- ENEC has established an Anti-Fraud and Misconduct Programme (AFMP) that supports prevention, detection, investigation and response towards fraud or misconduct incidents, and to instil honesty and ethical behaviour in ENEC’s culture and environment. The AFMP procedure provides a framework to promote responsible and secure whistleblowing. It serves to receive and address any concern or complaint regarding fraud and/ or misconduct. The AFMP comprises of four global reporting channels for reporting suspected incidents of fraud, fraudulent activity, or misconduct. Whistle-blowers can choose to stay anonymous through reporting via the following channels: i. Toll free hotline available in multiple languages 24/7 across several countries. ii. Dedicated email address for reporting concerns. iii. Dedicated Web Portal – Internal and External. iv. Provision to submit verbal/ written complaints using AFMP Reporting Forms. The AFMP highlights the significance associated with protection of whistle-blowers. It condemns and addresses any acts of retaliation against whistle-blowers for reporting complaints in good faith. In 2019, ENEC conducted multiple awareness sessions to create AFMP awareness and to instil honesty and ethical behavior in its culture and environment.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by ENEC, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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