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Annual Report 2015

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Anti-corruption policy

The Anti-corruption Policy is the main anti-corruption document of IDGC of the North-West which outlines interrelated principles, procedures, and actions stipulated by the Recommended Guidelines on Measures Developed and Approved by Organizations to Prevent and Combat Corruption, formulated and approved by the Ministry of Labor and Social Protection of the Russian Federation on November 08, 2013.

The Company performs anti-corruption monitoring of actions under the Company’s Anti-corruption Policy, identified cases of corruption and methods to handle them.

The key areas for anti-corruption monitoring are as follows:

  • review of the staff opinion on corruption in the Company and effectiveness of taken anti-corruption measures;
  • review of the implementation of anti-corruption measures stipulated by orders and instructions of thevCompany;
  • review and analysis of the statistics reports on any cases of corruption identified in the Company;
  • review of complaints from individuals and legal entities on cases of corruption in the Company;
  • review and analysis of measures taken in the Company to combat corruption;
  • analysis of publications about corruption in the Company in mass media.

PJSC IDGC of the North-West focuses on prevention of corruption and other non-compliance with the law. The Company developed measures aimed at identifying and eliminating cases for corruption:

  • created and improved the Anti-Corruption Policy section on the Company’s official website;
  • publishes information on implementation of the Anti-Corruption Policy in corporate periodicals;
  • performs anti-corruption expert review of orders and instructions and their drafts;
  • organized and exercises internal control;
  • sets competency and expertise requirements for any applicants for vacant positions at PJSC IDGC of the North-West, performs duly checks of the personal data submitted by the applicants.
  • In May 2015, PJSC IDGC of the North-West joined the Anti-Corruption Charter of the Russian Business. The Company

In May 2015, PJSC IDGC of the North-West joined the Anti-Corruption Charter of the Russian Business. The Company thus demonstrated its willingness to meet international and Russian anti-corruption laws and regulations, ethical standards of open and honest business practices.

The Anti-Corruption Charter of the Russian Business was developed by the Chamber of Industry and Commerce of the Russian Federation, Russian Union of Industrialists and Entrepreneurs, OPORA Of RUSSIA All-Russia Public SME Organization, and Delovaya Rossija, All-Russia Public Organization.

When assessing the trustworthiness of partners and contractors, the Company takes into account their anti-corruption status during business operations, including any anti-corruption programmes. Compliance with the anti-corruption principles is considered an important factor when entering into contracts, including the possibility of terminating any agreements if the anti-corruption principles are violated.

PJSC IDGC of the North-West developed and implemented a uniform mechanism for information check of the contractors’ ownership chain, including their beneficiaries (including end beneficiaries), handling of personal data when disclosing information on the ownership chain by contractors, compliance with the anti-corruption standards when purchasing, and conflict of interest management system.

In 2015, the employees of security units organized and performed 164 business audits with a total prevented damage of RUB 16.9 million. As a result, actions were taken against 292 Company employees, and employment was terminated with 17 of them, administrative sanctions were imposed on 105 employees, and 217 employees were deprived of a bonus.

In 2015, the security units continued to audit the bidding procedure, check bidders and potential winners, identify cases of affiliation, lobbying, and conflicts of interest. Potential contractors were checked in the bidding process to identify affiliation, 547 out of 4,582 potential contractors were found to be unsuitable. A total of 4,089 employees and their family members were checked for affiliation with the Company’s contractors and three of them were found to be affiliated.

A total of 841 candidates for vacant positions were checked to identify any personal interests or relationships with contractors and 42 unfavorable opinions were given. A total of 5,418 conflict of interest declarations were checked. Employees of branch security departments identified seven violations in completion of declarations although no conflicts of interest were found.