with assistance of CORPORATE GOVERNANCE PROFESSIONAL ASSOCIATION COMPANY TRANSPARENCY INDEX 2019 – UKRAINE TABLE OF CONTENTS FOREWORD 4 DISCLOSURE LEVEL IN CORPORATE 12 GOVERNANCE COMPONENT TRANSPARENCY INDEX DISCLOSURE 6 CONCLUSIONS LEVEL 18 DISCLOSURE LEVEL BY CATEGORY 8 24 COMPANY Company Transparency Index 2019 – Ukraine TRANSPARENCY INDEX 2019 RESULTS The Corporate Governance Professional Association (CGPA) and the Centre for CSR Development Ukraine (CSR Ukraine), supported by the Center for International Private Enterprise (CIPE), present the Company Transparency Index 2019, an assessment of Ukraine’s 100 largest taxpaying companies in 2019, as per the State Tax Service Data. The assessment analyzes the companies’ level of transparency in corporate governance and corporate social responsibility (hereinafter referred to as CSR) in 2019, before the pandemic caused by COVID-19. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 3 FOREWORD The Center for International Private Enterprise (CIPE) is I am really grateful to the partners of the Project – CSR Ukraine and The CSR Development Center has been implementing the Trans- proud to support this initiative which aims to encourage CIPE. Our cooperation made this study possible. We are pleased to find parency Index for eighth year in a row. But this year is special – companies to increase transparency and engagement out that there is a whole group of companies (banks) in Ukraine which this Transparency Index is conducted in partnership with two with the broader Ukrainian business ecosystem. not only follow popular trends but truly practice what they preach, well-known organizations – the Corporate Governance Profes- The companies on this list represent some excellent they promote specific values. These are the companies of the future. sional Association of and CIPE. I am grateful to the partners for best practices in Ukraine and can serve as leaders in They can be attractive to investors, partners and employees. this opportunity, support, and expertise. the country - creating a more inclusive, transparent It is also essential for companies to promote themselves system- The site is a tool for communication with stakeholders. That is atically and professionally, to establish a culture of openness and business operating environment that offers more why we evaluate not only general information about the company develop their unique style of “communication” with the business opportunities for more Ukrainians. The bright future of but also the results of the company’s work in many areas – hu- environment in the broadest sense of the word. Ukraine relies on more companies “doing the right thing” man rights, gender equality, corporate governance. That is im- and the leading companies highlighted in this report For the first time, we decided to pay attention to the personal lead- portant for investors, potential employees, NGOs, and the media. represent a strong foundation for the Ukrainian business ership style of senior executives, because we believe that if the The Transparency Index 2019 has updated components – cor- community to build on. company supports environmental projects, for example, the CEO should share these ideas and be personally involved in such types of porate governance, gender equality, and leadership. The Index Eric Hontz, projects not only as a manager but also as a citizen. results show interesting results: the overall level of transparency CIPE Deputy Regional Director, It was our first experience of conducting this particular type of such remains low, although state-owned companies perform better in Europe & Eurasia a comprehensive study; we are planning to continue in the future the Transparency Index than private ones. improving our methodology. Constructive criticism and any sugges- I hope the Transparency Index 2019 will help companies improve tions are welcome! We are open to cooperation. their sites and be inspired by the TOP-10 Index leaders’ example. Oleksandr Okuniev, Maryna Saprykina, Chairman of the Management Board of the Corporate Head of the Board for CSR Ukraine Governance Professional Association COMPANY TRANSPARENCY INDEX 2019 UKRAINE 5 TRANSPARENCY INDEX Average 25 disclosure level, DISCLOSURE 22,0 by Transparency 20,0 LEVEL Index 2019 category 20 15 A General information about the company and its CSR policy B Corporate governance 12.3 11.0 C Human rights 10.7 10 10.0 D Employment relationships 9.0 E Environmental protection CONTENT F CSR integration in the supply chain G Responsible consumption 6.0 5.2 5 5.5 5.3 H Community relations 4.8 4.4 The companies analyzed in this report disclose infor- 4.0 4.0 4.0 4.0 3.9 I Management and company leadership mation regarding their corporate governance policies, 3.0 2.5 3.4 3.0 employee relationships, environmental protection ini- 2.3 2.8 J Reporting 2.2 1.4 1.3 2.7 tiatives, and community relations the most frequently 1.5 1.1 1.4 on their respective websites. K Navigation 0.8 0.8 0.3 0.7 0.4 Human rights policies, level of CSR integration in sup- L Accessibility ply chains, and corporate leadership information are A B C D E F G H I J K L disclosed on companies’ websites the least. Maximum score The ten companies with the highest levels of transpar- ency in the Company Transparency Index 2019 disclose Average level of Transparency Index 2019 twice as much information in the Index Content and Re- porting categories than the other companies analyzed. Top 10 COMPANY TRANSPARENCY INDEX 2019 UKRAINE 7 DISCLOSURE LEVEL BY CATEGORY 24 companies placed 13 companies included 33 companies information about information about placed their mission, values, mission, values, and codes of and vision on their vision in their non- ethics on their websites financial reports websites GENERAL INFORMATION ABOUT THE COMPANY AND ITS CSR POLICY 7companies 26 companies, most of 20 companies mentioned the them were state- reported CSR existence of ethical owned, placed strategies or codes in their their development CSR goals on nonfinancial reports strategies on their their websites websites The largest Ukrainian companies typically place their company’s general information, profile, and, quite often, the company’s history and awards on their corporate websites. The practice of placing mission, goals, and strategy is not yet commonplace in the Ukrainian business environment. COMPANY TRANSPARENCY INDEX 2019 UKRAINE 9 GENERAL INFORMATION Notably, only two companies, PJSC “ArcelorMittal Kryvyi 2 ABOUT THE COMPANY Rih,” and JSC “Ukrgasvydobuvannya,” contain Sustainable AND ITS CSR POLICY Score, max Development Policies as approved documents. PrJSC Carlsberg Ukraine and JSC “Ukrgasvydobuvannya” created their CSR strategies and CSR goals in line with the UN’s Sustainable Development Goals. PrJSC Carlsberg Ukraine announced its Together Towards ZERO program in 2017, 1 a new sustainable development strategy of Carlsberg Group global company that Companies with highest contains four strategic goals: ZERO carbon footprint, ZERO water waste, ZERO irre- levels of general information 0.7 sponsible drinking, and ZERO accidents culture. In April 2020, JSC “Ukrgasvydobu- about the organizations and vannya” approved the Corporate Social Responsibility Policy of JSC “Ukrgasvy- their CSR policies 0.4 dobuvannya” in Relations with Commu- nities, Charitable and Non-governmental 0.3 Organizations. The initiative tracks the company’s progress towards achieving the 9 UN’s Sustainable Development Goals. 0.05 0.8 PrJSC Carlsberg The website of LLC “Lemtrans”, a company apart of the Ukraine SCM Group, contains the SCM Group’s Sustainable Devel- A B C D E opment Policy. Some companies provide information about their sus- tainable development strategies in their non-financial 7 Number Number 7.5 reports (e.g. JSB “Ukrgasbank”). JSC “Alfa-Bank” Other companies’ non-financial reports only contain companies of 20 general information about the significance of other com- 26 panies’ CSR policies. 37 A Mission and vision, values The integration of the UN’s Sustainable Development 40 B Company strategy Goals in Ukrainian companies’ CSR policies is extremely Maximum score 7 low. C CSR strategy or CSR goals LLC “Lemtrans” Seven Ukrainian companies mentioned the UN’s Sus- Average score of companies involved in the D Integration of the Sustainable Max possible score = 9 tainable Development Goals on their corporate website assessment Development Goals in the company’s CSR pages, and only two of them disclosed their clear com- strategy/goals (commitments) mitments to achieving the goals. Number of companies having placed relevant information E Code of ethics COMPANY TRANSPARENCY INDEX 2019 UKRAINE 11 CORPORATE Score, Score, max 2 GOVERNANCE Information disclosure level in the Corporate Governance component A Ownership structure: owners and beneficiaries B Company governance: governing bodies and their functional 1.1 responsibilities (Management Board, Board of Directors, Corporate Secretary) 1 C Membership of Board of Directors/Supervisory Board (informa- tion about members, independent members) 75 companies in the D Code (principles) of corporate governance 0.75 E Information for investors (reports, minutes, announcements, 0.64 Transparency presentations, etc.) Index 2019 placed F Policy on wages, bonuses and rewards for supervisory board 0.5 and management 0.4 0.4 information G Corporate social responsibility governance (entities or persons regarding corporate responsible for implementation of the CSR policy/strategy) 0.3 0.3 0.2 0.2 governance policies H Entity performing compliance functions, including existence of a committee for compliance and/or ethics within the 0.03 0.08 on their websites supervisory board 0.01 I Anti-corruption programme/policy A B C D E F G H I J K L M J Commissioner for anti-corruption programme K Communication channels for reporting of breaches (hotline, etc.) 4 1 5 L 37001 standard certification Number 14 12 M Stakeholder engagement plan 16 of companies of 23 30 Maximum score 34 35 Average score of companies involved in the 39 The companies usually disclose information about assessment 49 their governing bodies, management, and the elimina- tion of corruption for shareholders and investors.