POSITION
ABOUT ANTI-CORRUPTION POLICY

PROMSTROYIZOLYATSIYA LLC

Lipetsk 2015
 

1. Goals and objectives of implementing anti-corruption policy at the enterprise

The anti-corruption policy of Promstroyizolyatsiya LLC (hereinafter referred to as the enterprise) is a set of interrelated principles, procedures and specific measures aimed at preventing and suppressing corruption offenses in its activities.
The fundamental regulatory legal act in the field of combating corruption is Federal Law No. 273-FZ of December 25, 2008 “On Combating Corruption” (hereinafter referred to as Federal Law No. 273-FZ). The regulations governing the anti-corruption policy of the enterprise are also the Charter of Promstroyizolyatsiya LLC and other local acts.
In accordance with Article 13.3 of Federal Law No. 273-FZ, measures to prevent corruption taken in an organization may include:
1) identification of units or officials responsible for the prevention of corruption and other offenses;
2) cooperation of the organization with law enforcement agencies;
3) development and implementation of standards and procedures aimed at ensuring the integrity of the organization;
4) adoption of a code of ethics and official conduct for employees of the organization;
5) prevention and resolution of conflicts of interest;
6) preventing the preparation of unofficial reports and the use of false documents.
The enterprise's anti-corruption policy is aimed at implementing these measures.

2. Concepts and definitions used in politics

Corruption - abuse of official position, giving a bribe, receiving a bribe, abuse of power, commercial bribery or other illegal use by an individual of his official position contrary to the legitimate interests of society and the state in order to obtain benefits in the form of money, valuables, other property or services of a property nature, etc. property rights for oneself or for third parties, or the illegal provision of such benefits to the specified person by other individuals. Corruption is also the commission of the listed acts on behalf of or in the interests of a legal entity (clause 1 of Article 1 of the Federal Law of December 25, 2008 No. 273-FZ “On Combating Corruption”).
Anti-corruption - the activities of federal government bodies, government bodies of constituent entities of the Russian Federation, local governments, civil society institutions, organizations and individuals within the limits of their powers (clause 2 of Article 1 of the Federal Law of December 25, 2008 No. 273-FZ “ On anti-corruption"):
a) to prevent corruption, including identifying and subsequently eliminating the causes of corruption (prevention of corruption);
b) to identify, prevent, suppress, disclose and investigate corruption offenses (fight against corruption);
c) to minimize and (or) eliminate the consequences of corruption offenses.
An organization is a legal entity, regardless of its form of ownership, organizational and legal form and industry affiliation.
Counterparty is any Russian or foreign legal entity or individual with whom the organization enters into contractual relations, with the exception of labor relations.
Bribe is the receipt by an official, a foreign official or an official of a public international organization personally or through an intermediary of money, securities, other property, or in the form of illegal provision of services of a property nature, the provision of other property rights for the commission of actions (inaction) in favor of the bribe-giver or persons represented by him, if such actions (inaction) are within the official powers of the official or if, by virtue of his official position, he can contribute to such actions (inaction), as well as for general patronage or connivance in the service.
Commercial bribery is the illegal transfer of money, securities, other property to a person performing managerial functions in a commercial or other organization, the provision of property services to him, the provision of other property rights for the commission of actions (inaction) in the interests of the giver in connection with the official position held by this person provision (part 1 of article 204 of the Criminal Code of the Russian Federation).
Conflict of interest is a situation in which the personal interest (direct or indirect) of an employee (representative of the organization) affects or may affect the proper performance of his official (labor) duties and in which a contradiction arises or may arise between the personal interest of the employee (representative of the organization) and the rights and legitimate interests of the organization, which can lead to harm to the rights and legitimate interests, property and (or) business reputation of the organization of which he is an employee (representative of the organization).
Personal interest of an employee (representative of an organization) - the interest of an employee (representative of an organization) associated with the possibility of the employee (representative of an organization) receiving income in the form of money, valuables, other property or services of a property nature, or other property rights in the performance of official duties for themselves or for third parties persons

3.Basic principles of the organization’s anti-corruption activities

The system of anti-corruption measures at the enterprise is based on the following key principles:
1. The principle of compliance of the organization’s policies with current legislation and generally accepted standards.
Compliance of the implemented anti-corruption measures with the Constitution of the Russian Federation, international treaties concluded by the Russian Federation, the legislation of the Russian Federation and other regulatory legal acts applicable to the organization.
2. The principle of personal leadership example.
The key role of the organization’s management in creating a culture of intolerance towards corruption and in creating an intra-organizational system for preventing and combating corruption.
3. The principle of employee involvement.
Awareness of the organization's employees about the provisions of anti-corruption legislation and their active participation in the formation and implementation of anti-corruption standards and procedures.
4. The principle of proportionality of anti-corruption procedures to the risk of corruption.
The development and implementation of a set of measures to reduce the likelihood of an organization, its managers and employees being involved in corruption activities is carried out taking into account the corruption risks existing in the activities of this organization.
5. The principle of the effectiveness of anti-corruption procedures.
The use of anti-corruption measures in an organization that are low cost, ensure ease of implementation and bring significant results.
6. The principle of responsibility and inevitability of punishment.
The inevitability of punishment for the organization’s employees, regardless of their position, length of service and other conditions, if they commit corruption offenses in connection with the performance of their job duties, as well as the personal responsibility of the organization’s management for the implementation of the internal organizational anti-corruption policy.
7. The principle of openness
Informing contractors, partners and the public about the anti-corruption standards adopted in the organization for conducting activities.
8. The principle of constant control and regular monitoring.
Regular monitoring of the effectiveness of implemented anti-corruption standards and procedures, as well as control over their implementation.

3. Scope of the policy and the circle of persons covered by it

The main circle of persons covered by the policy are the employees of the enterprise who are in labor relations with it, regardless of their position and functions performed. The policy also applies to persons performing work for an enterprise or providing services on the basis of civil contracts.

4. Identification of company officials responsible for the implementation of anti-corruption policy

At the enterprise, the general director is responsible for combating corruption, based on established tasks, specifics of activity, staffing levels, organizational structure, and material resources.
The tasks, functions and powers of the General Director in the field of anti-corruption are determined by his Job Description.
These responsibilities include, but are not limited to:
. development of local regulations of the organization aimed at implementing measures to prevent corruption (anti-corruption policy, code of ethics and official conduct of employees, etc.);
. carrying out control measures aimed at identifying corruption offenses by employees of the organization;
. organizing a corruption risk assessment;
. receiving and considering reports of cases of inducement of employees to commit corruption offenses in the interests or on behalf of another organization, as well as cases of corruption offenses committed by employees, contractors of the lyceum or other persons;
. organization of filling out and reviewing declarations of conflict of interest;
. organizing training events on preventing and combating corruption and individual counseling for employees;
. providing assistance to authorized representatives of control, supervisory and law enforcement agencies when they conduct inspections of the organization’s activities on issues of preventing and combating corruption;
. providing assistance to authorized representatives of law enforcement agencies in carrying out measures to suppress or investigate corruption crimes, including operational investigative activities;
. assessing the results of anti-corruption work and preparing relevant reporting materials.

5. Defining and consolidating the responsibilities of employees and organizations related to preventing and combating corruption

The responsibilities of the organization's employees in connection with preventing and combating corruption are common to all employees of the enterprise.
The general responsibilities of employees in connection with preventing and combating corruption are the following:
. refrain from committing and (or) participating in the commission of corruption offenses in the interests or on behalf of the enterprise;
. refrain from behavior that may be interpreted by others as a willingness to commit or participate in the commission of a corruption offense in the interests of or on behalf of the enterprise;
. immediately inform the management of the organization about cases of inducing an employee to commit corruption offences;
. immediately inform the immediate superior and management of the organization about information that has become known about cases of corruption offenses committed by other employees, counterparties of the organization or other persons;
. inform the immediate superior or other responsible person about the possibility of a conflict of interest arising or arising for the employee.
In order to ensure the effective performance of the duties assigned to employees, procedures for their compliance are regulated.
Based on the provisions of Article 57 of the Labor Code of the Russian Federation, by agreement of the parties, the employment contract concluded with an employee upon hiring may include the rights and obligations of the employee and the employer established by this local regulatory act - “Anti-Corruption Policy”.
It is recommended to include general and special duties in the employment contract with an employee of the organization. Provided that the employee’s responsibilities in connection with preventing and combating corruption are stipulated in the employment contract, the employer has the right to apply disciplinary measures to the employee, including dismissal, if there are grounds provided for by the Labor Code of the Russian Federation, for committing unlawful actions that entailed failure to fulfill the labor duties assigned to him.

6. Establishing a list of anti-corruption measures, standards and procedures implemented by the enterprise and the procedure for their implementation (application)

Direction Event
Regulatory support, consolidation of standards of behavior and declaration of intentions Development and adoption of a code of ethics and official conduct of employees of the organization
Development and implementation of provisions on conflict of interests, declaration of conflict of interests
Development and adoption of rules regulating the exchange of business gifts and signs of business hospitality
Introduction to contracts related to the economic activities of the organization, a standard anti-corruption clause
Introduction of anti-corruption provisions into employee employment contracts
Development and introduction of special anti-corruption procedures Introducing a procedure for informing employees of the employer about cases of inducing them to commit corruption violations and a procedure for considering such reports.
Introducing a procedure for informing an employer about information that has become known to an employee about cases of corruption offenses committed by other employees, contractors of the organization or other persons and a procedure for considering such reports.
Introducing a procedure for informing the employer's employees about the occurrence of a conflict of interest and a procedure for resolving the identified conflict of interest
Introduction of procedures for the protection of employees who report corruption offenses in the organization’s activities.
Conducting periodic assessments of corruption risks in order to identify areas of the organization’s activities most exposed to such risks and develop appropriate anti-corruption measures.
Training and information for employees Annual familiarization of employees, against signature, with regulatory documents regulating the issues of preventing and combating corruption in the organization
Conducting training events on preventing and combating corruption
Organizing individual consultations for employees on the application (compliance) of anti-corruption standards and procedures
Ensuring compliance of the organization’s internal control and audit system with the requirements of the organization’s anti-corruption policy Carrying out regular monitoring of compliance with internal procedures
Carrying out regular monitoring of accounting data, the availability and reliability of primary accounting documents
Regular monitoring of the economic feasibility of expenses in areas with a high corruption risk: exchange of business gifts, entertainment expenses, charitable donations, remuneration to external consultants
Assessing the results of ongoing anti-corruption work and disseminating reporting materials Conducting regular assessments of the results of anti-corruption work
Preparation and distribution of reporting materials on the work carried out and results achieved in the field of anti-corruption

7. Corruption risk assessment

The purpose of assessing corruption risks is to identify specific processes and activities of the enterprise, the implementation of which is most likely to cause corruption offenses by employees of the organization, both for the purpose of obtaining personal benefit and for the purpose of obtaining benefit from the organization.
Assessing corruption risks is an essential element of anti-corruption policy. It allows you to ensure that the implemented anti-corruption measures comply with the specifics of the organization’s activities and rationally use the resources allocated to carry out work to prevent corruption.
Corruption risks are assessed both at the stage of developing an anti-corruption policy and after its approval on a regular basis.
Procedure for assessing corruption risks:
. present the activities of the organization in the form of separate processes, in each of which identify the constituent elements (subprocesses);
. highlight “critical points” for each process and identify those elements (subprocesses) during the implementation of which corruption offenses are most likely to occur.
. For each subprocess, the implementation of which is associated with a corruption risk, create a description of possible corruption offenses, including:
- characteristics of the benefit or advantage that can be received by the organization or its individual employees when committing a “corruption offense”;
- positions in the organization that are “key” for the commission of a corruption offense - the participation of which officials of the organization is necessary to make the commission of a corruption offense possible;
- probable forms of making corrupt payments.
. Based on the analysis, prepare a “map of the organization’s corruption risks” - a summary description of “critical points” and possible corruption offenses.
. Develop a set of measures to eliminate or minimize corruption risks.

8. Responsibility of employees for non-compliance with the requirements of the anti-corruption policy

Timely identification of conflicts of interest in the activities of employees of an organization is one of the key elements in the prevention of corruption offenses.
It should be noted that conflicts of interest can take many different forms.
In order to regulate and prevent conflicts of interest in the activities of its employees, the company adopted a Regulation on Conflict of Interest.
The regulation on conflict of interest is an internal document of the organization that establishes the procedure for identifying and resolving conflicts of interest that arise among employees of the organization in the course of performing their job duties.

Federal Law of December 6, 2011 No. 402-FZ
“On Accounting” establishes the obligation for all organizations to exercise internal control over business operations, and for organizations whose financial statements are subject to mandatory audit, there is also an obligation to organize internal control over accounting and preparation of financial statements.
The internal control and audit system of an organization can contribute to the prevention and detection of corruption offenses in the activities of the organization. At the same time, the greatest interest is in the implementation of such tasks of the internal control and audit system as ensuring the reliability and reliability of the financial (accounting) statements of the organization and ensuring compliance of the organization’s activities with the requirements of regulatory legal acts and local regulations of the organization. To do this, the internal control and audit system must take into account the requirements of the anti-corruption policy implemented by the organization, including:
. checking compliance with various organizational procedures and operating rules that are significant from the point of view of work to prevent and prevent corruption;
. control of documenting the operations of the organization’s economic activities;
. checking the economic feasibility of ongoing operations in areas of corruption risk.
Control over documenting business transactions is primarily associated with the obligation to maintain financial (accounting) reporting of the organization and is aimed at preventing and identifying relevant violations: preparation of unofficial reports, use of forged documents, recording of non-existent expenses, lack of primary accounting documents, corrections in documents and reporting, destruction documents and reports earlier than the deadline, etc.

9. The procedure for reviewing and making changes to the organization’s anti-corruption policy

This local regulatory act may be revised and changes may be made if the legislation of the Russian Federation changes. Specific aspects of anti-corruption policy can be carried out by developing additions and annexes to this act.

Briefly: we are for fair competition and against corruption.

I affirm:

General Director of Petrolab LLC

Mazaev Stanislav Yurievich

REGULATIONS ON ANTI-CORRUPTION POLICY

Petrolab LLC

1. GENERAL PROVISIONS

1.1. Terms and definitions:

1.2. This anti-corruption policy has been developed in order to protect the rights and freedoms of citizens, ensure the rule of law, law and order and public safety at Petrolab LLC.

1.3. The anti-corruption policy of Petrolab LLC is a set of interrelated principles, procedures and specific measures aimed at preventing and suppressing corruption offenses in the activities of this Organization. This policy defines the objectives, basic principles of anti-corruption and measures to prevent corruption offenses.

1.4. For the purposes of this document, the following basic concepts are used:

1.5. Corruption- abuse of official position, giving a bribe, receiving a bribe, abuse of power, commercial bribery or other illegal use by an individual of his official position contrary to the legitimate interests of society and the state in order to obtain benefits in the form of money, valuables, other property or services of a property nature, other property rights for oneself or for third parties or illegal provision of such benefits to the specified person by other individuals;

1.6. Anti-corruption- the activities of federal government bodies, government bodies of constituent entities of the Russian Federation, local governments, civil society institutions, organizations and individuals within the limits of their powers (clause 2 of Article 1 of the Federal Law of December 25, 2008 No. 273-FZ “On countering corruption"):

a) to prevent corruption, including identifying and subsequently eliminating the causes of corruption (prevention of corruption);

b) to identify, prevent, suppress, disclose and investigate corruption offenses (fight against corruption);

c) to minimize and (or) eliminate the consequences of corruption offenses.

1.7. Bribe- receipt by an official, a foreign official or an official of a public international organization personally or through an intermediary of money, securities, other property or in the form of illegal services of a property nature provided to him, the provision of other property rights for committing actions (inaction) in favor of the briber or those represented them of persons, if such actions (inaction) are included in the official powers of the official or if, by virtue of his official position, he can contribute to such actions (inaction), as well as for general patronage or connivance in the service.

1.8. Commercial bribery- illegal transfer to a person performing managerial functions in a commercial or other organization, money, securities, other property, provision of services of a property nature, granting other property rights for the commission of actions (inaction) in the interests of the giver in connection with the official position occupied by this person ( Part 1 of Article 204 of the Criminal Code of the Russian Federation).

1.9. Conflict of interest- a situation in which the personal interest (direct or indirect) of an employee (organization representative) affects or may affect the proper performance of his official (labor) duties and in which a contradiction arises or may arise between the personal interest of the employee (organization representative) and the rights and legal interests of the organization, which can lead to harm to the rights and legitimate interests, property and (or) business reputation of the organization of which he is an employee (representative of the organization).

1.10. Corruption offense- an act that has signs of corruption, for which a regulatory legal act provides for civil, disciplinary, administrative or criminal liability;

1.11. Corruption factor- a phenomenon or a set of phenomena that gives rise to corruption offenses or contributes to their spread;

1.12. Prevention of corruption- activities of Petrolab LLC on anti-corruption policy aimed at identifying, studying, limiting or eliminating phenomena that give rise to corruption offenses or contribute to their spread.

2. BASIC PRINCIPLES OF ANTI-CORRUPTION

2.1. Anti-corruption in the Russian Federation is carried out on the basis of the following principles:

Recognition, provision and protection of fundamental rights and freedoms of man and citizen;

Legality;

The inevitability of responsibility for committing corruption offenses;

Integrated use of political, organizational, information and propaganda,

Socio-economic, legal, special and other measures;

Priority application of measures to prevent corruption;

Cooperation of the state with civil society institutions, international organizations and individuals.

2.2 The system of anti-corruption measures in the Organization is based on the following key principles:

The principle of compliance of the organization's policies with current legislation and generally accepted standards.

Compliance of the implemented anti-corruption measures with the Constitution of the Russian Federation, international treaties concluded by the Russian Federation, the legislation of the Russian Federation and other regulatory legal acts applicable to the Organization;

The principle of personal leadership example.

The key role of the Organization’s leadership in creating a culture of intolerance towards corruption and in creating an intra-organizational system for preventing and combating corruption;

The principle of employee involvement.

Awareness of the organization's employees about the provisions of anti-corruption legislation and their active participation in the formation and implementation of anti-corruption standards and procedures;

The principle of proportionality of anti-corruption procedures to the risk of corruption.

The development and implementation of a set of measures to reduce the likelihood of the Organization, its managers and employees being involved in corruption activities is carried out taking into account the corruption risks existing in the activities of this Organization;

The principle of the effectiveness of anti-corruption procedures.

The use of anti-corruption measures in the Organization that are low cost, ensure ease of implementation and bring significant results;

The principle of responsibility and inevitability of punishment.

The inevitability of punishment for the Organization's employees, regardless of their position, length of service and other conditions, if they commit corruption offenses in connection with the performance of their job duties, as well as the personal responsibility of the Organization's management for the implementation of the internal organizational anti-corruption policy;

The principle of openness of work.

Informing contractors, partners and the public about the anti-corruption work standards adopted by the Organization;

The principle of constant control and regular monitoring.

Regular monitoring of the effectiveness of implemented anti-corruption standards and procedures, as well as control over their implementation.

3. GOALS AND OBJECTIVES OF ANTI-CORRUPTION POLICY

3.1. The policy reflects the commitment of Petrolab LLC and its management to high ethical standards and principles of open and honest conduct of business in the Organization, as well as maintaining its reputation at the proper level.

The organization sets itself the following goals:

Minimize the risk of involvement of Petrolab LLC, the Organization’s management and employees, regardless of their position, in corruption activities;

To form among employees and other persons a uniform understanding of Petrolab LLC’s policy of non-acceptance of corruption in all forms and manifestations;

Summarize and explain the main requirements of the anti-corruption legislation of the Russian Federation that may be applied in the Organization;

Establish the obligation of Petrolab LLC employees to know and comply with the principles and requirements of this Policy, key norms of applicable anti-corruption legislation, as well as measures to prevent corruption.

4. SCOPE AND RESPONSIBILITIES

4.1. The main circle of persons covered by the policy are the employees of the Organization who are in labor relations with it, regardless of their position and functions performed. The policy applies to persons, for example, individuals and (or) legal entities with whom the Organization enters into other contractual relations.

Anti-corruption conditions and obligations can be enshrined in contracts concluded by the organization with counterparties.

4.2. A number of responsibilities of employees in connection with preventing and combating corruption:

Refrain from committing and (or) participating in the commission of corruption offenses in the interests of or on behalf of the Organization;

Refrain from behavior that could be interpreted by others as a willingness to commit or participate in the commission of a corruption offense in the interests of or on behalf of the Organization;

Immediately inform the immediate supervisor / person responsible for implementing the anti-corruption policy / management of the Organization about cases of inducing an employee to commit corruption offenses;

Immediately inform the immediate superior / person responsible for implementing the anti-corruption policy / management of the Organization about information that has become known to the employee about cases of corruption offenses committed by other employees, contractors of the organization or other persons;

Inform the immediate superior or other responsible person about the possibility of a conflict of interest arising or arising for the employee.

4.3. An employee is prohibited from receiving remuneration from individuals and legal entities in connection with the performance of work duties (gifts, monetary remuneration, loans, services, payment for entertainment, recreation, transportation expenses and other remuneration).

4.4. The employee, among other things, is obliged to:

Notify the employer (his representative), the prosecutor's office or other government bodies about any persons contacting him for the purpose of inducing him to commit corruption offences;

Take measures to prevent any possibility of a conflict of interest and resolve the conflict of interest that arises;

Notify the employer (his representative) and his immediate superior about the conflict of interest that has arisen or the possibility of its occurrence, as soon as he becomes aware of it, in writing;

Transfer his securities, shares (participatory interests, shares in the authorized (share) capitals of organizations) into trust management in accordance with the civil legislation of the Russian Federation if the ownership of securities, shares (participatory interests, shares in the authorized (share) capitals organizations) leads or may lead to a conflict of interest.

4.5. All employees of Petrolab LLC must be guided by this Policy and strictly comply with its principles and requirements.

4.6. The General Director of Petrolab LLC is responsible for organizing all activities aimed at implementing the principles and requirements of this Policy, including the appointment of persons responsible for the development of anti-corruption measures, their implementation and control.

4.7. The tasks and functions of officials or those responsible for combating corruption must be established, among other things, in employment contracts and job descriptions.

4.8. The official's responsibilities include:

Development and submission for approval by the General Director of Petrolab LLC of draft local regulations of the Organization aimed at implementing measures to prevent corruption (anti-corruption policy, code of ethics and official conduct of employees, declaration of conflict of interest, etc.);

Carrying out control activities aimed at identifying corruption offenses by employees of the organization;

Organization of assessment of corruption risks;

Reception and consideration of reports of cases of inducement of employees to commit corruption offenses in the interests or on behalf of another organization, as well as cases of commission of corruption offenses by employees, contractors of the organization or other persons;

Organization of filling out and reviewing notifications of conflict of interest;

Organization of training events on preventing and combating corruption and individual counseling for employees;

Providing assistance to authorized representatives of control, supervisory and law enforcement agencies during their inspections of the organization’s activities on issues of preventing and combating corruption;

Providing assistance to authorized representatives of law enforcement agencies in carrying out measures to suppress or investigate corruption crimes, including operational investigative activities;

Conducting an assessment of the results of anti-corruption work and preparing relevant reporting materials to the management of the Organization.

5. APPLICABLE ANTI-CORRUPTION LEGISLATION

5.1. Petrolab LLC and all employees must comply with the norms of Russian anti-corruption legislation, established, inter alia, by the Criminal Code of the Russian Federation, the Code of the Russian Federation on Administrative Offenses, the Federal Law “On Combating Corruption” and other regulations, the main requirements of which are the prohibition of bribes, the prohibition of receiving bribes, the prohibition of bribery and the prohibition of mediation in bribery.

5.2. In view of the above, all employees of the Organization are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, from participating in corrupt practices, offering, giving, promising, asking and receiving bribes.

6. KEY PRINCIPLES OF ANTI-CORRUPTION POLICY

6.1. The General Director and officials of the Organization must form an ethical standard of uncompromising attitude towards any forms and manifestations of corruption at all levels, setting an example by their behavior and familiarizing all employees with the anti-corruption policy.

6.2. Petrolab LLC periodically identifies, reviews and evaluates corruption risks characteristic of its activities in general and for certain areas in particular.

6.3. Petrolab LLC takes measures to prevent corruption that are reasonably responsive to the identified risks.

6.4. Petrolab LLC makes reasonable efforts to minimize the risk of business relationships with counterparties that may be involved in corrupt activities, comply with the requirements of this Policy, and also provide mutual assistance to prevent corruption.

6.5. Petrolab LLC posts this Policy in the public domain on its official website on the Internet, openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all contractors, its employees and other persons.

Petrolab LLC helps to increase the level of anti-corruption culture by informing and systematically training employees in order to maintain their awareness of the Organization’s anti-corruption policy and master the ways and techniques of applying anti-corruption policy in practice.

6.6. In connection with possible changes over time in corruption risks and other factors affecting the activities of the Organization, Petrolab LLC monitors the implemented measures to prevent corruption, controls their compliance, and, if necessary, reviews and improves them.

7. INTERACTION WITH EMPLOYEES

7.1. Petrolab LLC requires its employees to comply with this Policy by informing them of the key principles, requirements and sanctions for violations.

7.2. Petrolab LLC organizes safe, confidential and accessible means of informing management about facts of bribery by persons providing services in the interests of a commercial organization or on its behalf. Proposals for improving anti-corruption measures and control, as well as requests from employees and third parties, may be sent to the general director via email address (info@site).

7.3. To develop an appropriate level of anti-corruption culture, introductory training is conducted for new employees on the provisions of this Policy and related documents, and periodic information events are held for existing employees in person and/or remotely.

8. WAIVER OF RESPONSE MEASURES AND SANCTIONS

8.1. Petrolab LLC declares that no employee will be subject to sanctions (including dismissal, demotion, deprivation of bonuses) if he reported an alleged fact of corruption, or if he refused to give or receive a bribe, commit commercial bribery or mediate in bribery.

9. INTERNAL FINANCIAL CONTROL

9.1. Internal financial control is aimed at creating a system of compliance with the legislation of the Russian Federation in the field of financial activities, internal procedures for drawing up and executing the budget (plan), improving the quality of preparation and reliability of financial statements and accounting, as well as increasing the efficiency of using budget funds.

9.2. The main purpose of internal financial control is to confirm the reliability of the Organization's accounting and reporting, compliance with the current legislation of the Russian Federation regulating the procedure for carrying out financial and economic activities. The internal control system is designed to ensure:

Accuracy and completeness of accounting documentation;

Timely preparation of reliable financial statements;

Prevention of errors and distortions;

Execution of orders and instructions of the head of the Organization;

Implementation of plans for the financial and economic activities of the Organization;

Safety of the Organization's property.

9.3. The main objectives of internal control are:

Establishing the compliance of ongoing financial transactions in terms of financial and economic activities and their reflection in accounting and reporting with the requirements of regulatory legal acts;

Establishing compliance of ongoing operations with regulations and the powers of employees;

Compliance with established technological processes and operations when carrying out functional activities;

Analysis of the Organization's internal control system, allowing to identify significant aspects affecting its effectiveness.

9.4. Internal control in the Organization is based on the following principles:

The principle of legality is strict and precise compliance by all subjects of internal control with the norms and rules established by the regulatory legislation of the Russian Federation;

The principle of independence - subjects of internal control, when performing their functional duties, are independent of the objects of internal control;

The principle of objectivity - internal control is carried out using actual documentary data in the manner established by the legislation of the Russian Federation, through the use of methods that ensure the receipt of complete and reliable information;

The principle of responsibility - each subject of internal control is responsible for improper performance of control functions in accordance with the legislation of the Russian Federation;

The principle of consistency is the implementation of control measures of all aspects of the activity of the object of internal control and its relationships in the management structure.

9.5. The Organization's internal control system includes the following interrelated components:

The control environment, which includes compliance with the principles of financial control, the professional and communicative competence of the Organization’s employees, their work style, organizational structure, assignment of responsibility and authority;

Risk assessment - which is the identification and analysis of relevant risks when achieving certain objectives that are interconnected at various levels;

Control activities that summarize policies and procedures that help ensure compliance with orders and instructions from management and the requirements of Russian legislation;

Activities on information support and information exchange aimed at timely and effective identification of data, their registration and exchange, in order to form among all subjects of internal control an understanding of the internal control policies and procedures adopted in the Organization and ensuring their implementation;

Monitoring the internal control system is a process that includes management and supervision functions, during which the quality of the internal control system is assessed.

9.6. Internal financial control in the Organization is carried out in the following forms:

Preliminary control. It is carried out before the start of a business transaction.

Allows you to determine how appropriate and legal a particular operation will be;

Preliminary control is carried out by the head of the Organization, his deputies, and the chief accountant;

Current control.

This is conducting a daily analysis of compliance with procedures for executing the budget (plan), maintaining accounting records, monitoring the expenditure of targeted funds for their intended purpose, assessing the efficiency and effectiveness of their expenditure. Current control is carried out on an ongoing basis by specialists who carry out accounting and reporting of the Organization;

Subsequent control is carried out based on the results of business transactions.

It is carried out by analyzing and checking accounting documentation and reporting, conducting inventories and other necessary procedures. To carry out subsequent control, an internal control commission may be created by order of the General Director. The commission must include accounting staff and representatives of other interested departments.

9.7. The accounting control system includes supervision and verification of:

Compliance with the requirements of the legislation of the Russian Federation regulating the procedure for carrying out financial and economic activities;

Accuracy and completeness of preparation of documents and accounting registers;

Preventing possible errors and distortions in accounting and reporting;

Execution of orders and instructions from management;

Control over the safety of the Organization's financial and non-financial assets.

9.8. Subsequent control is carried out through both scheduled and unscheduled inspections. Scheduled inspections are carried out at a certain frequency, approved by order of the General Director, as well as before the preparation of financial statements.

The main objects of scheduled inspection are:

Compliance with the legislation of the Russian Federation regulating the procedure for maintaining accounting records and accounting policies;

Correctness and timeliness of reflection of all business transactions in accounting;

Completeness and accuracy of documentation of transactions;

Timeliness and completeness of inventory; reliability of reporting.

During an unscheduled inspection, control is carried out on issues in relation to which there is information about possible violations.

9.9. Persons responsible for conducting the inspection analyze the identified violations, determine their causes and develop proposals for taking measures to eliminate them and prevent them from happening in the future.

The results of preliminary and current control are drawn up in the form of memos addressed to the head of the Organization, to which a list of measures to eliminate shortcomings and violations, if any, have been identified, as well as recommendations for avoiding possible errors may be attached.

9.11. The system of internal control subjects includes:

Head of the Organization and his deputies;

Internal Control Commission;

Managers and employees of the Organization at all levels.

9.12. The division of powers and responsibilities of the bodies involved in the functioning of the internal control system is determined by the internal documents of the Organization, including regulations on the relevant structural units, as well as organizational and administrative documents of the Organization and job descriptions of employees.

9.13. Subjects of internal control, within the framework of their competence and in accordance with their functional responsibilities, are responsible for the development, documentation, implementation, monitoring and development of internal control in the areas of activity entrusted to them.

9.14. Persons who have committed shortcomings, distortions and violations bear disciplinary liability in accordance with the requirements of the Labor Code of the Russian Federation.

9.15. The assessment of the effectiveness of the internal control system in the Organization is carried out by the subjects of internal control and is considered at special meetings held by the head of the Organization.

9.16. Direct assessment of the adequacy, sufficiency and effectiveness of the internal control system, as well as control over compliance with internal control procedures is carried out by the internal control commission.

Within the framework of these powers, the internal control commission submits to the head of the Organization the results of audits of the effectiveness of existing internal control procedures and, if necessary, proposals for their improvement developed jointly with the chief accountant.

9.17. The results of the subsequent control are formalized in the form of an act signed by all members of the commission, which is sent with an accompanying memo to the head of the Organization.

The inspection report must include the following information:

Verification program (approved by the General Director);

The nature and state of accounting and reporting systems, types, methods and techniques used in the process of carrying out control activities;

Analysis of compliance with the legislation of the Russian Federation regulating the procedure for carrying out financial and economic activities;

Conclusions about the results of control;

Description of the measures taken and a list of measures to eliminate shortcomings and violations identified during subsequent monitoring, recommendations for avoiding possible errors.

Employees of the Organization who have committed shortcomings, distortions and violations provide written explanations to the head of the Organization on issues related to the results of control.

9.18. Based on the results of the audit, the chief accountant of the Organization (or a person authorized by the head of the Organization) develops an action plan to eliminate identified deficiencies and violations, indicating the deadlines and responsible persons, which is approved by the General Director.

Upon expiration of the established period, the chief accountant immediately informs the head of the Organization about the implementation of measures or their non-fulfillment, indicating the reasons.

9.19. All changes and additions to this provision are approved by the General Director of Petrolab LLC.

9.20. If, as a result of changes in the current legislation of the Russian Federation, certain articles of this provision come into conflict with it, they lose force, and the provisions of the current legislation of the Russian Federation shall prevail.

10. MAKING CHANGES

10.1. If insufficiently effective provisions of this Policy or related anti-corruption measures of Petrolab LLC are identified, or if the requirements of the applicable legislation of the Russian Federation change, the General Director, as well as responsible persons, will organize the development and implementation of an action plan to review and amend this Policy and/or anti-corruption measures.

11. COOPERATION WITH LAW ENFORCEMENT AUTHORITIES IN THE FIELD

ANTI-CORRUPTION

11.1. Cooperation with law enforcement agencies is an important indicator of Petrolab LLC’s true commitment to declared anti-corruption standards of conduct.

11.2. This cooperation can take place in various forms:

The Organization may undertake a public obligation to report to the relevant law enforcement agencies about cases of corruption offenses that the Organization (its employees) become aware of.

The need to report to the relevant law enforcement agencies about cases of corruption offenses that have become known to the Organization may be assigned to the person responsible for preventing and combating corruption in this Organization.

The organization should undertake the obligation to refrain from any sanctions against its employees who reported to law enforcement agencies information about the preparation or commission of a corruption offense that became known to them in the course of performing their work duties.

11.3. Cooperation with law enforcement agencies may also take the form of:

Providing assistance to authorized representatives of control, supervisory and law enforcement agencies during their inspections of the organization’s activities on issues of preventing and combating corruption;

Providing assistance to authorized representatives of law enforcement agencies in carrying out measures to suppress or investigate corruption crimes, including operational investigative activities.

11.4. The management of the Organization and its employees should provide support in the identification and investigation by law enforcement agencies of facts of corruption, take the necessary measures to preserve and transfer to law enforcement agencies documents and information containing data on corruption offenses. When preparing application materials and responses to requests from law enforcement agencies, it is recommended to involve specialists in the relevant field of law in this work.

11.5. The management of the Organization and its employees must not allow interference in the performance of official duties by officials of judicial or law enforcement agencies.

12. LIABILITY FOR NON-PERFORMANCE (IMPROPER PERFORMANCE)

OF THIS POLICY

12.1. The General Director and employees of all divisions of Petrolab LLC, regardless of their position, bear responsibility, provided for by the current legislation of the Russian Federation, for compliance with the principles and requirements of this Policy.

12.2. Persons guilty of violating the requirements of this Policy may be brought to disciplinary, administrative, civil or criminal liability at the initiative of the administration of Petrolab LLC, law enforcement agencies or other persons in the manner and on the grounds provided for by the legislation of the Russian Federation.

Anti-corruption policy is an activity aimed at creating an effective anti-corruption system. The Anti-Corruption Policy defines the key principles and requirements aimed at preventing corruption and compliance with applicable anti-corruption laws by the company's management, its employees and other persons who may act on behalf of or on behalf of the company.

The anti-corruption policy of an organization is a set of interrelated principles, procedures and specific measures to prevent and suppress corruption offenses in the activities of this organization.

According to the position of the Russian Ministry of Labor, information about the anti-corruption policy implemented in the organization is recommended to be consolidated in a single document, for example with the same name “Anti-corruption policy (name of organization)”.

So, the company’s anti-corruption policy is its local regulatory act, developed and adopted in accordance with anti-corruption legislation, as well as the charter and other internal documents of the company.

In Russia, anti-corruption policy is developed in accordance with the provisions of the Federal Law of December 25, 2008 No. 273-FZ “On Combating Corruption” and Methodological Recommendations for the development and adoption of measures by organizations to prevent and combat corruption, approved by the Ministry of Labor and Social Protection of the Russian Federation on November 8 2013, taking into account the requirements of generally accepted principles and norms of international law and international treaties, as well as the UK Bribery Act (UK Bribery Act 2010).

Thus, the unified industry anti-corruption policy of the State Atomic Energy Corporation Rosatom and its organizations is the basis for the development of regulatory and methodological documents for any groups of processes insofar as they ensure the anti-corruption focus of these documents, and acts as a kind of anti-corruption constitution in this industry.

The anti-corruption policy of OJSC Magnitogorsk Iron and Steel Works is a basic document defining key principles and requirements aimed at preventing corruption and compliance with applicable anti-corruption legislation by the company, members of its board of directors and executive bodies, employees and other persons who may act on behalf of the company.

Based on the analysis of international standards for the implementation of anti-corruption behavior in companies, it is possible to determine the main content of the anti-corruption policy, which:

• - prohibits bribery;
• - requires compliance with anti-corruption laws applicable to the organization;
• - corresponds to the goals of the organization;
• - provides a basis for setting, reviewing and achieving anti-corruption goals;
• - includes the obligation to comply with the requirements of the anti-corruption management system;
• - encourages confidential reporting of your doubts without fear of reprisals;
• - contains a commitment to continuously improve the anti-corruption management system;
• - justifies the powers and independence of the anti-corruption enforcement service;
• - explains the consequences of failure to comply with the anti-corruption policy.

The anti-corruption policy should be:

• - formatted as documented information;
• - communicated in the appropriate language to the organization’s employees and business partners;
• — is made available, to the extent possible, to relevant interested parties.

Anti-corruption policy:

• - provides for the goals and objectives of the society’s anti-corruption policy;
• - determines persons responsible for combating corruption;
• - establishes the principles for building a risk management and internal control system in the field of preventing and combating corruption;
• - provides a set of measures aimed at preventing and combating corruption;
• - establishes the responsibility of employees for non-compliance with the requirements of anti-corruption legislation and internal documents of the company in the field of combating corruption;
• - determines the procedure for reviewing / making changes to the policy.

Main goal of anti-corruption policy company is to provide all employees with the necessary practical knowledge of detecting and preventing corruption crimes, as well as knowledge of how to act in accordance with anti-corruption legislation, to guarantee business without corruption.

The company's anti-corruption policy as a local regulatory act (Fig. 3) should be developed with the involvement of all interested departments (for example, financial, legal department, human resources department, etc.), organizing meetings and collective discussions of the draft future document. In addition, it would not be amiss to familiarize the rest of the company’s employees first with the project, and then with the final version of the adopted anti-corruption policy - for this, the Russian Ministry of Labor advises posting the document on the organization’s Internet portal.

Rice. 3.

Companies oppose corruption in all forms and vigorously enforce anti-corruption policies in their own operations and in the activities of those who provide and supply goods and services to them.

Who is this policy for? For all company employees and employees who work with the company or play a role in the delivery of goods and services, in the development, marketing, sale or purchase of products (services) on behalf of the company. The policy is also implemented for distributors, agents and other partners.

The strategic objective of the policy is to embed anti-corruption standards in the behavior of employees and directors at all levels, in all companies and countries directly or indirectly involved in activities with likely high levels of corruption. This also applies to all third parties associated with or acting on behalf of the company.

Each employee is required to read the contents of the company's anti-corruption policy and perform their work and responsibilities in accordance with its principles. Any violation of the anti-corruption policy will result in disciplinary action, including dismissal from the company and legal action.

The principle of transparency in policy means that each branch of the company must ensure that employees are aware of its anti-corruption policy. The company must also ensure that its business partners are fully aware of it.

Training is part of a comprehensive compliance program dedicated to the fight against corruption. The training program will enable participants to identify and manage company operational risks.

Most often, thematic trainings and seminars for employees concern theory (for example, legal liability for violating anti-corruption norms, clarification of the provisions of local regulations, repetition of the procedure for identifying corruption, etc.). It is effective to train employees in a playful way - reviewing cases, conducting individual and collective master classes (you can distribute roles among participants, assign tasks and ask them to resolve a controversial issue in accordance with the company's anti-corruption policy).

For example, an employee of Nika LLC, as a private individual, received a significant discount on products from Sever LLC. The job responsibilities of this employee include monitoring the quality of goods provided to Nika LLC by contractors, including Sever LLC.

Question: what decision should management make regarding this employee?

Answer options: remove the employee from performing his duties or hold a conversation with him, during which he will be advised to refuse the discount provided by the counterparty in order to avoid a conflict of interest.

Amendments: This document will be amended from time to time to reflect changes in the law or the company.

Every employee of the company must demonstrate through their behavior the importance of fighting corruption.

Companies must actively combat corruption, avoiding even the appearance of it in any business agreements.

Companies are responsible for following the rules associated with the giving and receiving of benefits and gifts and refrain from giving or accepting illegal benefits and gifts that unduly influence both business decisions and regulatory authorities.

Companies prohibit all forms of bribery, regardless of the size of the kickback or gift.

Since one of the most common violations of the anti-corruption policy concerns the rules of giving gifts on behalf of the company, it is recommended to include the following provision in the anti-corruption policy: “if an employee receives a gift or several gifts in connection with his work activity, the total value of which exceeds 15 thousand rubles. (or any other amount that the company determines), he is obliged to inform the compliance department (or any other alternative department) or the responsible employee by sending an email message to the authorized department.” In terms of preventing conflicts of interest, the anti-corruption policy should be supplemented with the following phrase: “Employees are prohibited from offering, giving or accepting any gifts, including in the form of services or benefits, if this may cause a conflict of interest.”

All suppliers of goods and services, as well as the company's partners, are required to conduct business in accordance with such an anti-corruption policy. The company is obliged to terminate any relationships with suppliers of goods and services and partners who do not express a willingness to follow the anti-corruption policy.

Why should companies fight corruption?

Corruption is a widespread phenomenon in corporate and public life in both developing and developed countries and comes in many forms. Corruption can exist at any time in any country under any form of government.

Corruption has serious economic consequences. Global economic losses amount to more than $1 trillion. Every year in the United States, corruption distorts national and international trade, reducing competition. This may result in poor quality products. In addition, it undermines the effectiveness of the public and private sectors by determining people's positions based on reasons of favoritism rather than competence. Corruption can also jeopardize humanitarian efforts, preventing the rescue of those in need

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Question

Please help me prepare a sample form of the LLC's anti-corruption policy, a form of the code of ethics and official conduct at the enterprise, a sample of the development and implementation of standards and procedures aimed at ensuring the integrity of the organization; The prosecutor's office requested this from our LLC in its letter.

Answer

For details on how to develop anti-corruption measures at an enterprise, see the recommendation in the rationale.

Danila Aktyanova, internal auditor of the Science and Innovation division of the state corporation Rosatom, member of the International Institute of Internal Auditors

Nikolai Chudakov, editor-in-chief of the USS "Sistema Lawyer"

How to develop a corporate program to combat corruption, fraud and theft

Unscrupulous actions on the part of individual company employees can cause significant financial and reputational damage to the company. To prevent this, it is necessary to build in advance a system of measures to combat corruption, fraud and theft.

They will help develop such a system (approved by the Ministry of Labor and Social Protection of the Russian Federation on November 8, 2013; hereinafter referred to as Methodological Recommendations).

The fact is that from January 1, 2013, all organizations are required to develop and implement anti-corruption measures (“On Combating Corruption”). Until recently, this obligation was declarative, since there were no regulations that would detail it. The situation changed only with the release.

Moreover, they can be useful not only for formally fulfilling the above-mentioned obligation to prevent and combat corruption. Abuses committed in companies are often not limited to corruption alone. Focusing on, a lawyer can develop a comprehensive program aimed at countering:

• fraud,
• commercial bribery
• asset theft,
• infringements on intellectual property and trade secrets of the organization.

Development of a Program to Combat Corruption, Fraud and Theft

It is recommended to consolidate the basic principles, list and order of implementation of individual activities in a single document, which can be called “Anti-Corruption Policy”, as proposed in the Methodological Recommendations. You can choose another name - for example, the Comprehensive Program to Combat Corruption, Fraud and Theft (hereinafter referred to as the Program), which will more accurately reflect the essence of the activities being carried out.

The preparation of the draft Program is optimally divided into the following stages.

1. Project development. The program can be prepared either by external consultants or by the company itself. By order of the organization, it is necessary to form a working group with the participation of representatives of financial, legal, personnel services, economic security departments, internal audit and external communications (PR). To increase the authority of the working group, it is advisable for it to be headed by a representative of senior management.

2. Initial discussion of the working version of the document. It is advisable to involve the widest possible range of company employees in the discussion. To get feedback from employees, the project should be posted on the corporate portal.

3. Coordination. The program must be agreed upon with structural units, formalized in the form of a local regulatory act and approved by order of the organization, which will make it mandatory for all employees to comply with its provisions.

4. Familiarization. The approved Program is brought to the attention of company employees, for example, through an email notification. Then employees must confirm the fact of familiarization with their signature.

The approved Program is posted on the internal intranet portal, as well as in other corporate media (newspapers, brochures, posters, leaflets). As an example, see the Program approved by the state corporation Rosatom.

If necessary, a transition period can be provided from the moment the Program is adopted until the start of its operation. During the transition period, internal seminars are initiated for employees to explain the main provisions of the Program.

Determination of the Program curator

The work to combat corruption and abuse is complex and involves many services. However, to increase efficiency, it is recommended to identify a structural unit that will coordinate the work of other departments of the company in this area.

In the current practice of Russian business, this function, as a rule, is assigned to the economic security division (more often) or the internal audit department (less often). In Russian divisions of foreign companies, such tasks are usually performed by a specialized Compliance division.

To reduce the risk of opposition from unscrupulous employees, it is necessary to subordinate the head of the department responsible for overseeing the Program directly to the General Director.

A typical diagram of the possible distribution of areas of responsibility for the implementation of the Program is presented in the table.

Implementation of Program activities

The reasons for corporate abuse by staff, as a rule, are the following main factors:

• self-justification. Low corporate culture in an organization leads to employees justifying the wrongdoings they have committed (“low wages,” “everyone takes kickbacks,” etc.);
• possibilities. The lack of an effective internal control system creates the preconditions for individual employees to commit abuses with a low probability of being detected;
• pressure. The presence of external or internal circumstances forcing employees to violate established rules and procedures.

The program should include a plan of activities aimed at preventing, preventing, identifying, and investigating corruption and abuse through the coordinated work of the organization’s structural units.

System of measures to prevent corruption and other abuses

A key tool for preventing abuse is the inclusion of anti-corruption provisions in employment contracts with employees and contracts with business partners. It is also important to improve corporate culture, create an atmosphere of honesty and rejection of corruption, fraud and theft on the part of the majority of company employees.

1. Introduction of anti-corruption provisions into employee employment contracts

The following responsibilities can be included in employee employment contracts:

• refrain from committing and (or) participating in the commission of corruption offenses in the interests or on behalf of the company;
• refrain from behavior that may be interpreted by others as a willingness to commit or participate in the commission of a corruption offense in the interests of or on behalf of the organization;
• immediately inform the immediate supervisor (or the person responsible for the implementation of the anti-corruption program, or the management of the organization) about cases of inducing an employee to commit corruption offenses;
• immediately inform the immediate superior (or the person responsible for the implementation of the anti-corruption program, or the management of the organization) about information that has become known to the employee about cases of corruption offenses committed by other employees, contractors of the organization or other persons;
• inform the immediate supervisor or other responsible person about the possibility of a conflict of interest arising or arising for the employee.

At the same time, the main mechanism for assigning additional responsibilities to employees related to preventing and combating corruption is the Labor Code of the Russian Federation.

Rationale

By agreement of the parties, the employment contract may include the rights and obligations of the employee and employer established by labor legislation and other regulatory legal acts containing labor law norms, local regulations, as well as the rights and obligations of the employee and employer arising from the terms of the collective agreement and agreements. Such rules are established by the Labor Code of the Russian Federation.

If the employment contract contains the above obligations, the employer has the right to apply disciplinary measures (including dismissal) to the employee for committing unlawful actions that resulted in the employee’s failure to fulfill his job duties.

The company's management may instruct the legal department to prepare or analyze a draft local regulation regulating the procedure for notifying the employer:

• about cases of inducing an employee to commit abuses;
• about information that has become known to the employee about cases of such actions.

It is quite acceptable to take as a basis the procedure already applied in the civil service. Thus, they propose to turn to the experience of the Ministry of Health and Social Development of Russia, given in “On methodological recommendations on the procedure for notifying a representative of the employer (employer) about the facts of appeal in order to induce a state or municipal employee to commit corruption offenses, including a list of information contained in notifications, issues of organizing verification of these information and procedure for registering notifications.”

2. Introduction to contracts related to the economic activities of the organization, a standard anti-corruption clause

4. Management of conflicts of interest

Timely identification of conflicts of interest in the activities of company employees is a key element in preventing abuse.

5. Conducting a campaign

An effective tool for improving corporate culture can be a PR campaign aimed at promoting an honest model of behavior and the inevitability of punishment for those who commit abuses. This objectively helps reduce the risk of negative incidents. Such a campaign may include publication of thematic materials in corporate media, informing employees about the activities carried out to implement the Program and the results obtained, and thematic competitions among employees.

If necessary, the legal department, at the request of the PR service, participates in claims work with an external communications agency. For example, if the result obtained does not comply with the technical specifications established in the contract.

System of measures to prevent, detect and investigate abuse

In addition to the preventive measures listed above, the Anti-Corruption, Fraud and Theft Program involves specific actions to identify and suppress violations in the company. Such actions can be divided into several groups.

1. Assessment of corruption risks in business processes and development of control procedures

Corruption risk assessment is aimed at identifying those specific business processes and business operations in the organization’s activities, the implementation of which carries the highest risk of employees of the organization committing corruption offenses.

An algorithm for conducting such an assessment is given, which includes the following steps:

• present the company’s activities in the form of separate business processes, in each of which component elements (subprocesses) are identified;
• identify “critical points”, subprocesses during the implementation of which abuses are most likely to occur, as well as identify indicators (signs) of abuses in each process;

Examples of possible indicators of abuse

The presence of abuse in the work of the organization’s employees may be indicated by:

• providing expensive gifts, paying for transport and entertainment services, issuing loans on preferential terms, providing other valuables or benefits to external consultants, state or municipal employees, employees of affiliates and contractors;
• purchases or sales at prices significantly different from market prices;
• questionable cash payments;
• a decrease in financial indicators (revenue, profit) for individual segments compared to the previous period (signs of unreasonably large discounts or purchases from suppliers at inflated prices for personal compensation);
• payment to an intermediary or external consultant of a fee that exceeds the normal fee for the organization or the fee for this type of service;
• an increase in the number of defects compared to previous periods (writing off a new product as defective due to falsification of primary documents for writing off inventory items);
• the presence of discrepancies in the physical volumes of inventory items released into production compared to the volumes of inventory items received from the warehouse;
• payment for services the nature of which is uncertain or in doubt;
• identification of duplicate primary documents (signs of “doubling” payments within the same counterparty, while part of the money may end up in the employee’s personal account);
• the presence of discrepancies in the weight of the cargo measured at the time of receipt at the company and upon dispatch from the supplier’s warehouse (signs of theft of part of the cargo during transportation);
• increase in expenses for materials purchased by company employees with funds received on account (the risk of fictitious write-off of materials for the purpose of subsequent theft).

• describe the benefits and advantages that can be obtained by committing the abuse; positions that are key to the commission of corruption offenses; probable forms of making unreasonable payments. For example, “receiving kickbacks from suppliers by the purchasing manager.”

The analysis will allow us to draw up a “map of the company’s corruption risks,” which will allow us to develop a set of measures to eliminate or minimize them.

Approximate control procedures in individual business processes are presented in the table.

2. Implementation of technical controls

Theft in a company can be reduced by equipping facilities with engineering and technical security equipment and special instrumental monitoring. Such means may include:

• access control systems;
• lighting and alarm systems in warehouses;
• video surveillance systems.

In addition, it is worth using (with the written consent of candidates) a polygraph when applying for a job involving the handling of expensive goods and materials, conducting systematic checks of the safety of goods and materials and funds, and also concluding agreements on financial liability with employees.

The legal department is responsible for legalizing the use of technical controls. For example, lawyers should check the following points:

• local regulations and employment contracts provide for the possibility of using video surveillance by the company;
• employees are familiarized with the order to introduce a video surveillance system, and information about its availability is posted at their workplaces;
• the equipment is certified and is not included in the list of special technical means intended for secretly obtaining information.

3. Create a hotline for reporting abuse

Another effective tool for preventing and identifying corruption and abuse can be the creation of a hotline for receiving messages in a company. The hotline may include: a multi-channel telephone (with free incoming calls from anywhere in the world), email, and a mailbox.

The legal service provides assistance in the development of local regulations regulating the reception and processing of received messages while maintaining and maintaining the anonymity of callers. Confidentiality agreements must be concluded with hotline operators.

4. Investigation of abuse

Based on the results of identified facts of corruption and other abuses, it is necessary to conduct an internal investigation in full accordance with the procedure established by current legislation.

The legal service provides assistance to the economic security, personnel and internal audit departments in terms of consolidating the evidence base and compliance with the established rules for bringing disciplinary action and dismissal procedures.

In addition, the legal department can take part in the development of regulations for internal investigations.

Anti-corruption policy(hereinafter referred to as the Policy) defines the key principles and requirements aimed at preventing corruption and compliance with applicable anti-corruption legislation by the management of STEP LOGIC LLC (hereinafter referred to as the Company), its employees and other persons who may act on behalf or on behalf of the Company.

The Policy is a local regulatory act of STEP LOGIC LLC, developed and adopted in accordance with anti-corruption legislation, as well as the Charter and other internal documents of the Company.

The policy is a documented procedure of the quality management system.

The requirements of the Policy are mandatory for all employees of the Company, its representatives, as well as for other persons, in cases where the corresponding responsibilities are specified in contracts with them.

The policy comes into force from the moment of its approval by the General Director and is valid until the introduction of the new Anti-Corruption Policy. Changes to the current policy are made by order of the company.

• Criminal Code of the Russian Federation
• Federal Law of December 30, 2001 No. 195-FZ “Code of the Russian Federation on Administrative Offences”
• Federal Law of December 25, 2008 No. 273-FZ “On Combating Corruption”

Anti-corruption legislation– a set of laws in force in the Russian Federation and other states in which the company does business itself or through its partners, regulating social, economic, civil relations, as well as other regulatory legal acts providing for measures to prevent corruption, suppress corruption offenses and liability for them .

Applicable anti-corruption laws

The company, its management and employees must comply with the norms of anti-corruption legislation established, including by the Criminal Code of the Russian Federation, Federal Law dated December 30, 2001 No. 195-FZ “Code of the Russian Federation on Administrative Offences”, Federal Law dated December 25, 2008 . No. 273-FZ “On Combating Corruption” and other regulations, the main requirements of which are:

• The prohibition of bribery is the prohibition of giving or promising to provide any financial or other benefit/advantage with the intent to induce a person to perform his official duties improperly.
• Prohibition of accepting bribes – prohibition of receiving or agreeing to receive any financial or other benefit/advantage for performing one’s official duties improperly.
• The prohibition of commercial bribery is the prohibition of providing or promising to provide (directly or through third parties) to an official/public person any financial or other benefit/advantage for the purpose of influencing the performance of his official duties, to obtain/retain business or to provide a competitive or other advantage for the company.
• Prohibition of mediation and connivance in bribery - the presence in the company of adequate procedures aimed at preventing the giving or receiving of bribes by persons associated with such a company in order to acquire or retain business, to ensure commercial and competitive advantages.

General provisions

The management and all employees of the Company are strictly prohibited from directly or indirectly, personally or through third parties, participating in corrupt practices, offering, giving, promising, asking for and receiving bribes or making payments to simplify administrative, bureaucratic and other formalities in any form, including in the form of funds, valuables, services or other benefits for oneself or third parties, organizations, including commercial organizations, government and self-government bodies, civil servants.

Objectives of the Policy.
The policy reflects the commitment of the Company and its management to high ethical standards and the principles of open and honest business conduct, as well as the Company’s desire to improve corporate culture, adhere to best corporate governance practices and maintain the Company’s business reputation at the highest possible level.
The company sets itself the following goals:

• Minimizing the risk of involvement in corruption activities of the Company itself, its management and employees, regardless of their position.
• Formation among contractors, employees and other persons of a uniform understanding of the Company’s policy of non-acceptance of corruption in all forms and manifestations.
• Generalization and explanation to all employees of the basic requirements of anti-corruption legislation that may apply to the Company, its management and employees.
• Establishing the responsibilities of Company employees to know and comply with the principles and requirements of this Policy, the key norms of applicable anti-corruption legislation, as well as participate in activities to prevent corruption.

Leadership mission.
The Company's management, including the General Director, must establish an ethical standard of uncompromising attitude towards any forms and manifestations of corruption at all levels, setting an example by their behavior and familiarizing all Company employees and contractors with the anti-corruption policy.
The Company enshrines the principle of non-acceptance of corruption in all forms and manifestations in the implementation of daily activities and strategic projects, including in interaction with contractors, representatives of authorities, self-government, political parties, its employees and other persons.
Periodic risk assessment.
The Company periodically identifies, reviews and evaluates corruption risks specific to its activities in general and to individual areas in particular.
Adequate anti-corruption measures.
The General Director is responsible for organizing all activities aimed at implementing the principles and requirements of this Policy, including the appointment of persons within the company responsible for the development of anti-corruption measures, their implementation and control.
The Company takes measures to prevent corruption that are reasonably responsive to the identified risks.
Checking counterparties.
The Company makes reasonable efforts to minimize the risk of business relationships with counterparties who may be involved in corrupt activities, for which purpose the counterparties' tolerance to bribery is checked, including their willingness to include anti-corruption clauses in contracts, as well as to provide mutual assistance for ethical business conduct and preventing corruption.
Information and training.
The company's management and the responsible persons appointed by them communicate this Policy to all employees, explain and clarify the requirements of this Policy in relation to the production tasks of employees.
The company openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of anti-corruption legislation by its employees and contractors.
Monitoring and control.
Due to possible changes over time in corruption risks and other factors affecting business activities, the Company monitors the implemented adequate measures to prevent corruption, controls their implementation, and, if necessary, reviews and improves them.

Donation and entertainment expenses

Donations and entertainment expenses related to business hospitality that employees may make on behalf of the Company to other individuals and organizations, or that employees may receive from other individuals and organizations in connection with their work for the Company must meet the following criteria:

• be directly related to the legitimate purposes of the Company’s activities, for example, with the presentation or completion of business projects, successful execution of contracts, or with national holidays, the Company’s birthday;
• be reasonable and reasonable;
• must be agreed upon by the company management;
• not represent a hidden reward for a service, action, inaction, connivance, patronage, provision of rights, making a certain decision on a transaction, agreement, permission, etc. or attempting to influence the recipient for any other illegal or unethical purpose;
• not create reputational risks for the Company, its employees and other persons in the event of disclosure of information about donation expenses or entertainment expenses;
• do not contradict the principles and requirements of this Policy and other internal documents of the Company, the norms of the legislation of the Russian Federation.

Donations on behalf of the Company, its employees and representatives to third parties in the form of funds, both cash and non-cash, in any currency are not permitted.
Souvenir products (low-cost products) with the Company's logo, provided at exhibitions, open presentations, forums and other marketing events in which the Company officially participates, are allowed and considered as image or information materials.

Conflict of interest

The company's management and employees refrain from any actions that could cause a conflict of interest for any of their business partners and contractors.
If a Company employee has a conflict of interest, he must inform his immediate supervisor or company management about it and provide full information about the substance of the conflict of interest to the persons responsible for investigating this situation.
Responsible persons when conducting investigations of conflicts of interest must act in accordance with internal documents regulating this process of the company.

Participation in charitable activities

The Company does not finance charitable and sponsorship projects in order to obtain specific commercial benefits.
Information about charitable and sponsorship activities is published on the Company’s website or otherwise disclosed.
The company may decide to participate in charitable events aimed at creating the image of the organization as a socially responsible business. At the same time, the budget and plan for participation in the event are agreed upon with the General Director.

Participation in political activities

The company does not finance political parties, organizations and movements.

Interaction with government officials

The company refrains from paying any expenses for government employees and their close relatives (or in their interests) in order to obtain commercial advantages in specific projects, including expenses for transport, accommodation, food, entertainment, PR campaigns, etc., or their receipt of other benefits at the expense of the Company.

Interaction with employees

The Company requires its employees to comply with this Policy by informing them of the key principles, requirements and sanctions for violations.
To create an appropriate level of anti-corruption culture, periodic information events are held for employees in person and/or remotely.
Compliance by the Company's employees with the principles and requirements of this Policy is taken into account when forming a personnel reserve for promotion to higher positions, as well as when imposing disciplinary sanctions.

Interaction with intermediaries and other persons

The Company and its employees are prohibited from engaging or using intermediaries, partners, agents, joint ventures or other persons to carry out any actions that are contrary to the principles and requirements of this Policy or anti-corruption laws.
In order to comply with the principles and requirements provided for in this Policy, the Company proposes the inclusion of anti-corruption conditions (clauses) in contracts with intermediaries, contractors, partners, agents and other persons.

Introduction of books and records

All financial transactions must be accurately, correctly and with a sufficient level of detail reflected in the Company's accounting records, displayed in documents and available for verification.
The Company has appointed employees who bear personal responsibility, as provided for by the current legislation of the Russian Federation, for the preparation and provision of complete and reliable financial statements within the time limits established by the applicable legislation.
Distortion or falsification of the Company's financial statements is strictly prohibited and is considered fraud.

Policy Alert

Any employee or other person in case of doubts about the legality or compliance with the goals, principles and requirements of this Policy of his actions, as well as actions, inactions or proposals of other employees, contractors or other persons who interact with the Company, must inform a senior manager, who , if necessary, will provide recommendations and clarification regarding the current situation.

Waiver of sanctions

The Company declares that no employee will be subject to sanctions (including dismissal, demotion, loss of bonus) if he reports suspected corruption or if he refuses to give or receive a bribe, commit commercial bribery or mediate in bribery, including if, as a result of such refusal, the Company incurred lost profits or did not receive commercial and competitive advantages.

Audit and control

The Company regularly conducts external audits of financial and economic activities, control over the completeness and correctness of data reflected in accounting records and compliance with the requirements of the legislation of the Russian Federation and internal documents regulating the company's processes, including the principles and requirements established by this Policy.

Making changes

If insufficiently effective provisions of this Policy or the Company's anti-corruption measures related to it are identified, or if the requirements of anti-corruption legislation change, the General Director and responsible persons will organize the development and implementation of an action plan to review and amend this Policy and/or anti-corruption measures.

Responsibility for failure to comply with anti-corruption policy

All employees of the Company, regardless of their position, bear personal responsibility for compliance with the principles and requirements of this Policy, as well as for the actions (inaction) of persons subordinate to them who violate these principles and requirements.
Responsibility for non-compliance with the anti-corruption policy is established in accordance with the current legislation of the Russian Federation.
The company is obliged to conduct internal audits and investigations into each reasonable suspicion or established fact of corruption.