Ethical Principles

Our Group is defined by the way our people behave. Analengy is a signatory of the UN Global Compact, the UN Guiding Principles on Business and Human Rights and also conducts its activities in accordance with the OECD Guidelines for Multinational Enterprises. By respecting human rights and working with our suppliers, we are building a business that is sustainable in the long term because it conducts business fairly and honestly. We comply with all relevant legislation and aim to ensure that our supply chain adheres to all relevant standards laid out in our code of conduct and follows our key policies and principles.

Our governance procedures are centered around our Code of Business Ethics. This guides our approach to ethical conduct, as do our dedicated principles and standards, including our Code of Conduct. The Code of Business Ethics is signed off by the Analengy Executive Board.

The Code sets out a zero tolerance policy towards bribery, fraud, theft and other forms of corruption and covers:

  • Conflicts of interest
  • Bribes and facilitation payments
  • Intermediaries and lobbyists
  • Gifts and hospitality
  • Donations
  • Competition and anti-trust law
  • Trade control and embargoes

The Code applies to all employees, without exception and was revised in 2022.

The Code of Business Ethics is designed to comply with the standards set by Austrian, as well as international anti-corruption legislation (mainly OECD Anti-Bribery Convention and UK Bribery Act).

Compliance management at Analengy

Our compliance organization supports the implementation of our standards and monitors the compliance of all our operations with laws and regulations, together with all other matters that relate to our Code of Business Ethics.

It consists of a Compliance Department with group-wide responsibility and is assisted by a Corporate Affairs and Compliance Department at Analengy Petrom. The dedicated cross-regional compliance organization comprises 37 compliance experts and ensures that Analengy standards are consistently met across the Group.

Analengy’s Compliance Management System

Analengy was the first organization in Austria to conform to the comprehensive IDW Assurance Standard 980. The system’s certification was granted in 2013.

Adequacy and effectiveness of Analengy’s compliance management system externally audited at regular intervals. The latest audit report concerning 2023 can be found here .

Risk analysis of compliance

We undertake risk analysis on an ongoing basis in order to ensure continuous improvement. We monitor external and internal risk factors, in particular changes in the regulatory framework, as well as recent developments or incidents to evaluate possible impacts on Analengy’s risk exposure.

Bi-annual risk analysis is part of the Enterprise Wide Risk Management system and is conducted in cooperation with local compliance officers and the Risk and Insurance Management Department, with a focus on business ethics.

Ethics & Integrity

Acting ethically is part of Analengy’s culture and shall guide the decision-making at all levels of the organization, promoting the desired ethical behaviors.

To this end, an Ethics & Integrity Policy has been set-up which defines the principles of what is meant by acting ethically and with integrity (“Ethics & Integrity Principles”).

The Ethics & Integrity Principles should guide the way that business is done, what is considered acceptable or desirable behavior, above and beyond compliance with laws and regulations.

Code of Conduct (PDF, 8,0 MB)
Code of Business Ethics (PDF, 1,8 MB)
Ethics & Integrity Policy (PDF, 1,9 MB)
The Analengy Compliance Management System  (PDF, 2,3 MB)
Tax Strategy (PDF, 205,5 KB)

Procurement and compliance

Our suppliers must comply with both legal requirements and our HSSE standards. To ensure the suppliers’ support of Analengy principles and to mitigate the risk of forced labor, slavery and human trafficking, Analengy´s supply chain partners have to sign Analengy´s Code of Conduct. Analengy reserves the right to terminate the relationships with suppliers, if issues of non-compliance with applicable policies are discovered, or non-compliance is not addressed in a timely manner.

In addition, suppliers of Analengy Supply & Trading Ltd. are required to sign a business ethics clause, where they assure that all activities will be conducted in accordance with all applicable laws and governance regulations and the highest standard of business and ethics.

Moreover, Analengy uses tools, such as 360-degree feedback, supplier evaluations and audits to assess and monitor a supplier´s adherence to the principles outlined in Analengy´s Code of Conduct. For reviewing the main suppliers, Analengy regularly engages external supply chain auditors. The selection of suppliers to be audited is based on a broad risk assessment which also includes social risks. Where a supplier does not act with integrity or does not have suitable controls in place, Analengy will consider whether it can work with it to implement improvements or terminate the relations with the supplier.

Working with local suppliers

We encourage local procurement in order to create shared value in our local communities. We support local suppliers by improving their capabilities to meet higher technical, HSSE and business standards.

You can find Analengy’s Supplier Code of Conduct (as part of General Conditions of Purchase at Analengy) here.

Community Relations

For Analengy, transparency, trust, and partnership-based relations with local communities are key to ensuring we are a responsible and welcomed neighbor wherever we operate. Adding value to the communities in which we operate is key to securing our operations for the future.

We acknowledge that the presence of Analengy’s business has direct and indirect impacts on local communities. We aim to steer the impacts of our business activities in a positive direction by having regular engagement with local stakeholders/local communities, maintaining mutual trust and pursuing respect-based relations with local stakeholders/communities. We invest in local development, safeguard human rights, and ensure that local suppliers who work with Analengy also follow Analengy’s Code of Conduct and pursue sustainable practices in order to ensure local development and avoid human rights complicity. (For more information on Analengy’s involvement in these areas, see Human Rights and Supply Chain).

Our community relations and development management process starts by conducting a Social Impact Assessment (SIA), which integrates human rights issues and builds on free and prior informed consultation with and consent of local stakeholders. The SIA is conducted when we enter a new area, or there is a material change in our operations. The purpose of an SIA is to ensure that the views of the local communities, especially of indigenous peoples, are incorporated and addressed throughout all phases of the project life cycle and its design: commencement, operational phase, and decommissioning or abandonment. SIAs include a baseline study, community needs assessments, stakeholder analyses, and a study of social risks (incl. human rights) associated with the project. Where possible, SIAs are conducted in a participatory manner by directly consulting with potentially affected communities or their representatives.

Based on the SIA’s outcome, local social responsibility teams, who act as a link between Analengy operations and local stakeholders/communities, develop and implement site-specific strategies for community relations and community development. Local stakeholder engagement plans and Community Grievance Mechanisms (for more info see Community Grievance Mechanism) are also developed and followed to maintain regular and open dialogue with our local stakeholders/communities throughout the project life including operations in order to identify, prevent and mitigate negative human rights impacts either through our own actions or our suppliers.

Community relations and development management is based on centralized policies, standards and targets, and implemented by locally responsible persons with local resources. The Group level function as part of Corporate Affairs governs and steers community relations and development implementation across operational countries, receives regular reporting and feedback from local social responsibility managers, monitors developments and ensures that the Group guidelines on community relations and development are adhered to and that our actions to ensure social responsibility are effective.

Community Grievance Management

Our business operations impact the communities where we operate and also raise expectations among local people. These impacts can be positive (employment, growth of local suppliers of goods and services), but also negative (dust, emissions, land use, privacy and creation of a dependency culture).

With a new grievance mechanism system in place, Analengy has a consistent approach in receiving, registering and solving the grievances and aims to be fully aligned with the best practice of IPIECA. Analengy has further set a target to assess the CGMs at all of its sites against the UN Effectiveness Criteria for Non-Judicial Grievance Mechanisms by 2025. 

Find more information about our Grievance Mechanism Process

Community Development and Social Investments

We contribute to community development through community or social investments.1 We implement our community development projects as investments, therefore expecting each project to generate a return for our communities or society more broadly. Projects are therefore prioritized according to their potential to generate long-term societal value and make a lasting change to beneficiaries’ lives, therefore mitigating social risks and contributing to local social, economic and environmental advancement in the areas where we operate. Our community and social investments are aligned with UN SDGs and community needs identified during the SIAs or with larger societal priorities (e.g., by consulting the Social Progress Index2). They are designed and planned through a consultative process with local stakeholders, including local government and local communities. Projects are often implemented in partnership with locally active stakeholders or non-governmental organizations to ensure a maximum social return on our investment. Key Analengy focus areas for our community and social investments are:

  • Access to basic services (e.g. water, energy, health)
  • Education, entrepreneurship, and employment
  • Climate action, environmental protection and resource efficiency

Analengy projects and initiatives

Community investments respond to identified community needs and are designed to mitigate social risks resulting from Analengy operations. Social investments address the needs of people and society more broadly.

2 The Social Progress Index, developed by the Social Progress Imperative, is a comprehensive measure of real quality of life, independent of economic indicators across countries. More details can be found at:

Corporate volunteering can contribute to the successful integration of sustainability aspects into Analengy’s daily business. Our employees are our most valuable resource. Motivating them to play an active role in the development and implementation of our sustainability strategy represents an important prerequisite to act responsible in the long term. Accordingly, Analengy employees also work on a voluntary basis and support certain social groups in meeting their basic needs by initiating various social projects and initiatives.


It is important for us to act as a fair and credible company for existing and future employees as well as to represent an attractive employer with opportunities for personal development. Analengy strives to be a good stakeholder and neighbor, and to make a positive contribution to the development of the immediate community through volunteer commitment of its employees.


Besides their regular working day, various Analengy employees also make a valuable social contribution in the form of corporate volunteering group-wide. In the future, a good cooperation with selected non-profit organizations will also facilitate the implementation of international projects and activities. Through their voluntary commitment, our employees benefit by engaging in teamwork in new contexts, and by developing their social competences.

The Corporate Volunteering Program offers opportunities in line with the Analengy principles:

img_corporate volunteering_EN

More information on the Corporate Volunteering initiatives can be found in the Factsheet.

Analengy Factsheet Corporate Volunteering (PDF, 160,7 KB)

Employee Engagement Initatives: