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This version of the Consolidated Sustainability Statetment is a translation form the original material, which was prepared in Romanian. All possible care has been
taken to ensure that the translation is an accurate representation of the original text. However, in all matters of interpretation of information, views or opinions, the
original language version of our Consolidated Sustainability Statement takes precedence over this statement.
9.2.2 G1-3: Prevention and detection of corruption and bribery
During the year there was no specific anti-corruption policy, but a document is in preparation
and is expected to be approved in the first semester of 2025.
Through Government Decision no. 1269/2021 the National Anti-corruption Strategy 2021-2025
was adopted. This national strategy is aligned with international frameworks, such as GRECO
and the Cooperation and Verification Mechanism, as well as their associated objectives. In this
context, ROMGAZ Group has adopted the Declaration on the Commitment to the Organizational
Integrity Agenda within the framework of the National Anti-Corruption Strategy 2021–2025, as
well as the Integrity Plan 2022–2025. These documents, publicly available on the Company
website, reinforce the company's stance on condemning all forms of corruption, conflicts of
interest, and incompatibilities, recognizing them as factors that undermine the company’s
objectives and public trust.
Provisions relating to corruption and bribery are included in the Code of Ethics and Business
Conduct, under Subchapter III 2. Anti-corruption and anti-fraud.
Romgaz
Since August 2023, the company has implemented an operational procedure for identifying,
analyzing, and managing corruption risks.
Romgaz employs an integrated system for corruption prevention and detection, which includes
internal procedures such as:
• Identification, analysis and managing corruption risks;
• Managing reports and ensuring whistleblower protection;
• Preventing potential conflicts of interest.
Additionally, the company applies the Code of Ethics and Business Conduct, provides
confidential reporting mechanisms, offers training programs and periodic employee awareness
sessions, and conducts internal audits of critical processes (e.g., procurement, contracting,
contract monitoring, etc.). Romgaz’s leadership remains committed to establishing adequate
and effective financial and non-financial controls to ensure the identification, monitoring, and
mitigation of fraud and corruption risks.
Furthermore, Romgaz conducted a corruption vulnerability assessment for each operation. An
operation is considered an organizational unit within Romgaz, as defined by the Organization
and Functioning Regulation, and may include branches, divisions, departments, centers,
offices, services, teams, workshops, sections, agencies, and storage facilities, according to
internal organizational documents and decisions. The assessment covered 100% of Romgaz’s
organizational units. At the Company level, the system procedure “Inventory of Sensitive
Functions” is applied. Following the analysis, out of 134 activities, 20 activities representing
14.92% were identified as having a corruption risk. The assessment highlighted several risks,
with high-risk areas including: procurement, investment, human resources, information
technology and telecommunications, financial, legal, drilling, exploration, production, land
formalities and commercial operations.
Regarding the independence of investigators or the Inquiry Committee from the management
chain involved, the Disciplinary Investigation Committee is appointed by decision of the CEO
and consists of 3-5 members, including a Chairperson and a Secretary. To ensure the objectivity
of the process, disciplinary investigations are conducted crosswise between branches and
headquarters, avoiding the direct involvement of individuals from organizational structures that
may have connections to the case under review. Additionally, the committee includes a legal
advisor and a union representative as observers to help ensure the impartiality of the
investigations.
The Disciplinary Investigation Committee’s report is submitted to the CEO, who decides
whether to approve it. The report is then forwarded to the Anti-Fraud and Ethics Department
or the Ethics Advisor, who is responsible for drafting the decision to establish the committee.
In cases involving conflicts of interest, the Ethics Advisor informs the CEO and proposes forming
a mixed committee, including representatives from legal services, human resources, the Ethics