4.3

Anticorruption policy

The Anticorruption PolicyNo.78-ref was developed to form a consistent approach to implementation of requirements from Article 13.3 of the Federal LawNo.77-ref. The single policy contains a set of interrelated principles, procedures and activities focusing on development and implementation of measures combating corruption: exposure and elimination of corruption factors (prevention); exposure, prevention and suppression of corruption and other infringements; minimization and/or liquidation of corruption consequences. In 2015 the Company has set the following goals in line with the Anticorruption Policy:

  • implementation of requirements stated in Article 13.3 of the Federal LawNo.77-ref;
  • creation of efficient legal and practical tool combating corruption;
  • improvement of Company’s anticorruption regulatory base;
  • prevention of corruption and other infringements, enforcement of liability for corruption actions;
  • forming of single interpretation of Company’s position towards rejection of any corruption acts by partners, contractors, members of governing and oversight bodies;
  • forming of anticorruption corporate consciousness;

IDGC of Urals (OAO) adheres to the following principles in line with the Anticorruption Policy:

  • Compliance of the policy with legislation in force and generally accepted standards;
  • Respect of legitimate rights and interests, protection of reputation of employees, partners, contractors; protection of commercial secrets while combating corruption;
  • Efficiency of anticorruption procedures: execution of anticorruption measures, simple to be implemented and facilitating achievement of tangible results;
  • transparency of business: making partners, contractors and general public aware of anticorruption standards of the Company.

Company’s transparency with regard to combating corruption crimes ended up in joining the Anticorruption Charter of Russian business on 25.05.2015. The corporate web-site has a section, containing information on anticorruption policy, single Anticorruption Policy No.78-ref, as well as forms of corruption whistleblowing.

  • There is also a special procedure for collection, examination and processing of reports from entities (employees, contractors and other individuals) with regard to possible corruption symptoms in the Company;
  • We also prepared a bylaw for reporting on gifts received by the employees during service, submission, evaluation and sale of such gifts as well as remittance of funds from sales;
  • We also introduced a new bylaw on contract approval procedure, containing anticorruption clause, to form a single interpretation of Company’s position towards rejection of any corruption acts by partners and contractors.

Liabilities, undertaken by the Company to prevent corruption, are aimed at preventive control of Company’s operations. Pursuant to legislation in force and bylaws of Rosseti’s and IDGC of Urals (OAO), we collect, examine and consolidate information on beneficiaries of contractors, incl. beneficiaries of IDGC of Urals (OAO) and its SACs. The owners of any contractor are thoroughly examined.

In line with the bylaw on collection, examination and processing of reports from entities (employees, contractors and other legal entities and individuals) with regard to possible corruption symptoms in the Company, we disclosed means of corruption whistleblowing on our corporate web-site. In 2015 we collected five reports on possible corruption cases. We also arranged a procedure when administrative staff of the Company fills in declarations of conflicts of interest on an annual basis. 1,032 employees are subject to declaring. Results are examined and approved by the Company’s conflict commission. Procurements are regularly monitored by an expert from the unit, liable for prevention of corruption activities.

2016 and mid-term goals:

  • establishment of efficient practical tools for corruption prevention;
  • forming of single interpretation of Company’s position towards rejection of any corruption actions by partners, contractors, employees and members of governing and oversight bodies;
  • minimization of a risk when the Company is stained by corruption.