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.
FOREWORD
The Center for International Private Enterprise (CIPE) is proud to support this initiative which aims to encourage companies to increase transparency and engagement with the broader Ukrainian business ecosystem. The companies on this list represent some excellent best practices in Ukraine and can serve as leaders in the country - creating a more inclusive, transparent business operating environment that offers more opportunities for more Ukrainians. The bright future of Ukraine relies on more companies “doing the right thing” and the leading companies highlighted in this report represent a strong foundation for the Ukrainian business community to build on.
Eric Hontz,
CIPE Deputy Regional Director,
Europe & Eurasia
I am really grateful to the partners of the Project – CSR Ukraine and CIPE. Our cooperation made this study possible. We are pleased to find out that there is a whole group of companies (banks) in Ukraine which not only follow popular trends but truly practice what they preach, they promote specific values. These are the companies of the future. They can be attractive to investors, partners and employees. It is also essential for companies to promote themselves systematically and professionally, to establish a culture of openness and develop their unique style of “communication” with the business environment in the broadest sense of the word. For the first time, we decided to pay attention to the personal leadership style of senior executives, because we believe that if the company supports environmental projects, for example, the CEO should share these ideas and be personally involved in such types of projects not only as a manager but also as a citizen. It was our first experience of conducting this particular type of such a comprehensive study; we are planning to continue in the future improving our methodology. Constructive criticism and any suggestions are welcome! We are open to cooperation.
Oleksandr Okuniev,
Chairman of the Management Board of the Corporate
Governance Professional Association
The CSR Development Center has been implementing the Transparency Index for eighth year in a row. But this year is special – this Transparency Index is conducted in partnership with two well-known organizations – the Corporate Governance Professional Association of and CIPE. I am grateful to the partners for this opportunity, support, and expertise. The site is a tool for communication with stakeholders. That is why we evaluate not only general information about the company but also the results of the company’s work in many areas – human rights, gender equality, corporate governance. That is important for investors, potential employees, NGOs, and the media. The Transparency Index 2019 has updated components – corporate governance, gender equality, and leadership. The Index results show interesting results: the overall level of transparency remains low, although state-owned companies perform better in the Transparency Index than private ones. I hope the Transparency Index 2019 will help companies improve their sites and be inspired by the TOP-10 Index leaders’ example.
Maryna Saprykina,
Head of the Board for CSR Ukraine
TRANSPARENCY INDEX DISCLOSURE LEVEL
The companies analyzed in this report disclose information
regarding their corporate governance policies,
employee relationships, environmental protection initiatives,
and community relations the most frequently
on their respective websites.
Human rights policies, level of CSR integration in supply
chains, and corporate leadership information are
disclosed on companies’ websites the least.
The ten companies with the highest levels of transparency
in the Company Transparency Index 2019 disclose
twice as much information in the Index Content and Reporting
categories than the other companies analyzed.
DISCLOSURE
LEVEL
BY CATEGORY
GENERAL INFORMATION
ABOUT THE COMPANY
AND ITS CSR POLICY
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.
GENERAL INFORMATION
ABOUT THE COMPANY
AND ITS CSR POLICY
The website of LLC “Lemtrans”, a company apart of the
SCM Group, contains the SCM Group’s Sustainable Development
Policy.
Some companies provide information about their sustainable
development strategies in their non-financial
reports (e.g. JSB “Ukrgasbank”).
Other companies’ non-financial reports only contain
general information about the significance of other companies’
CSR policies.
The integration of the UN’s Sustainable Development
Goals in Ukrainian companies’ CSR policies is extremely
low.
Seven Ukrainian companies mentioned the UN’s Sustainable
Development Goals on their corporate website
pages, and only two of them disclosed their clear commitments
to achieving the goals.
CORPORATE
GOVERNANCE
75 companies in the
Transparency
Index 2019 placed
information
regarding corporate
governance policies
on their websites
The companies usually disclose information about
their governing bodies, management, and the elimination
of corruption for shareholders and investors.
Some companies mention the existence of an anti-corruption
program, a commissioner for anti-corruption
programs, and available communication channels in
their Management Reports. The information disclosure
level concerning the implementation of companies’
anti-corruption programs is also low. In 2019,
only JSC “Ukrainian Railways,” NNEGC “Energoatom,”
PrJSC “Ukrhydroenergo,” SE “Ukraine Sea Port Authority,”
JSC CB “Privatbank,” and SC “Ukrposhta” posted
the results of anti-corruption implementation on their
websites. Only PJSC “Credit-Agricole Bank” provided
data regarding certification of the ISO 37001 standard,
“Anti-bribery management systems – Requirements
with guidance for use,” on the website. In our opinion,
disclosures on the prevention of corruption are higher
among state-owned enterprises and banks compared to
other companies due to the approval of relevant regulatory
documents.
The publication of information regarding rewards to
management staff is a relatively new concept to the
Ukrainian business environment. Only JSC “NJSC “Naftogaz
of Ukraine” placed this information on its website.
The practice of disclosing information concerning ownership
structure, the establishment of corporate social
responsibility governance structures, and stakeholder
engagement is not common in the Ukrainian companies’
corporate governance system.
Only 5 companies, JSB “Ukrgasbank,” JSC Ukrtransnafta,
PJSC “ArcelorMittal Kryvyi Rih,” JSC “Ukrainian Railways,”
and NNEGC “Energoatom” published their stakeholder
engagement plans. JSC “First Ukrainian International
Bank,” JSC “Ukrainian Railways,” NPC “Ukrenergo,”
and JSC “Farmak” mentioned departments or persons
responsible for their CSR policies on their corporate
website pages.
CONCLUSIONS
Ukrainian companies do not regard corporate websites
as an effective tool of transparency or an efficient
stakeholder of communication channels. The fact that
the companies analyzed in this report provide more
information about their CSR policies or CSR practices
rather than the implementation of CSR policies and
practices supports this conclusion. Implementation
results of CSR policies and practices are most often
provided by the companies in their non-financial and
management reports.
Companies disclose information regarding their policies
and programs concerning environmental protection,
employee relationships, community relations, and some
corporate governance aspects (company management,
membership of supervisory boards, information for investors,
anti-corruption programs) the most frequently.
There is no information (perhaps, no implementation
practice as well) regarding the protection of human
rights, CSR integration in the supply chain, and management
and company leadership.
Only 6 companies published their 2019 nonfinancial
reports on their websites. Companies most likely postponed
the deadlines of non-financial reporting due to
the COVID-19 pandemic and the lack of normative and
legal regulation influenced the collection and analysis
of management reports.
State-owned
enterprises have
higher indicators
of transparency
than private
companies
in every
Transparency
Index component
More than a half of the companies among the Transparency
Index Top 10 are state-owned. In our opinion,
this is a positive sign of corporate governance reform in
Ukrainian state-owned enterprises.
The highest disclosure level is demonstrated by companies
in financial sector, transportation, and electricity,
many of them are state-owned.