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Social responsibility and corporate sustainability report 2015
RU

Anti-Corruption Activities

Main Principles and Tasks of Anti-Corruption Policy

The anti-corruption policy is an element of the internal control and risk management system of Federal Grid Company providing a set of measures to prevent corruption, reduce the risk of Company’s financial damage, reputational risks and risks of penalties to be imposed on the Company for bribery of officials.

Due to amendment of the anti-corruption legislation and Federal Grid’s joining the Anti-Corruption Charter of the Russian Business, a new revision of Federal Grid’s Anti- Corruption Policy was developed as a part of improvements of its anti-corruption activities and approved by Federal Grid’s Board of Directors in 2015.

The Anti-Corruption Policy describes a complex of interrelated procedures and specific measures to prevent and oppose the corruption inside the Company and to comply with clause 260 of the Corporate Governance Code in the part defining measures to form the elements of corporate culture, organisational structure, rules and procedures preventing corruption.

The anti-corruption policy has been in effect in the Company since 2012. Its new revision was approved in 2015.

Managing Anti-Corruption Activities

Federal Grid’s Anti-Corruption Policy is implemented based on the following principles:

  • full compliance of the Anti-Corruption Policy with applicable legislation and generally accepted rules;
  • zero tolerance towards corruption in all its forms and manifestations that means an absolute prohibition for managers and employees and other persons acting on behalf or in the interests of the Company to participate in corrupt practices directly or indirectly, personally or through any intermediary;
  • development of a corruption zero-tolerance culture and an internal anti-corruption system;
  • strict observance of legitimate rights and interests, business reputation of employees, partners and counterparties as well as non-disclosure of commercial secrets during implementation of anti-corruption measures;
  • personnel regular update and involvement in the development and implementation of anti-corruption standards and procedures;
  • business transparency: communication of anticorruption standards adopted by the Company to partners, counteragents and public;
  • responsibility and unavoidability of punishment for corruption for all employees irrespective of their position, length of service with the Company;
  • implementation of efficient anti-corruption measures easy for use and highly effective;
  • constant identification and scoring of corruption risks typical for the Company with consideration of its strategic development plans;
  • availability of the anti-corruption control system and regular assessment of the efficiency of its procedures targeted to minimize corruption risks; procedures are transparent, clear, feasible and adequate to identified corruption risks;
  • thorough due diligence review of counteragents to minimise reputational, financial and operating risks caused by interaction with them;
  • constant monitoring and continuous control of the implementation of anti-corruption procedures by managers and employees. G4-DMA

Federal Grid’s anti-corruption tasks are the following:

  • meet the requirements of Federal Anti-Corruption Law No. 273-FZ dated 25 December 2008;
  • perform compliance control, including anti-corruption compliance control;
  • set up an effective anti-corruption legal mechanism;
  • create an effective practical tool to implement anticorruption measures (including the approval of the anticorruption programme);
  • improve the legal framework for anti-corruption actions and interaction with state agencies handling anticorruption issues;
  • prevent corruption-related offences and ensure the responsibility for corruption and other offences;
  • build awareness and uniform understanding among shareholders, partners, counteragents, governance and control bodies, employees of the Company’s zero tolerance towards corruption in all its forms and manifestations;
  • minimise the risk of the Company’s involvement in corrupt activities;
  • build an anti-corruption corporate culture.

Implementation of Anti-Corruption Policy

In 2015, the Anti-Corruption Policy of Federal Grid Company was further developed in the following areas.

Anti-Corruption Focus Areas in 2015

Improvement of Federal Grid’s anti-corruption management system The Audit Committee of Federal Grid’s Board of Directors was added to the anti-corruption management system.
Regulatory framework development To minimise corruption risks in the course of exchange of business gifts and entertainment as well as to implement a set of measures set forth by RF Government Resolution No. 10 dated 09 January 2014 “On reporting by certain categories of persons on receipt of gifts in connection with their official capacity or implementation of their official duties, hand-over and evaluation of gifts, their sale/purchase and booking of proceeds from their sale”:
  • the Regulation on exchange of business gifts and reporting by employees of Federal Grid’s Executive Office on receipt of gifts in connection with their official capacity or implementation of their official duties, on hand-over and evaluation of gifts, their sale/purchase and booking of proceeds from their sale was approved by Administrative Order No. 347 of Federal Grid Company dated 26 August;
  • respective regulations of Federal Grid’s branches and subsidiaries were approved;
  • working commissions of the Company’s Executive Office and branches were set up to take decisions whether to sell or otherwise dispose business gifts to support Federal Grid’s activities were set up.
Administrative Order of Federal Grid Company No. 207 “On Approval of the Regulation on Conflicts of Interest Management” dated 25 April 2014 was amended pursuant to Federal Law No. 285-FZ dated 05 October 2015 “On amendment…”. G4-41
Company’s involvement in anti-corruption collective initiatives G4-15 In accordance with Anti-Corruption Law No. 273-FZ dated 25.12.2008 and Methodic Guidelines for development and implementation of anti-corruption measures approved by the RF Ministry of Labour and Social Protection on 8 November 2013, one of the measures preventing corruption is the involvement in collective anti-corruption initiatives.
Pursuant to the above requirements Federal Grid Company joined the Anti-Corruption Charter of the Russian Business in 2015 and was included into the Consolidated Register of Charter Members (certificate No. 2041 dated 13 March 2015).
The solemn ceremony of awarding the Certificate of Joining the Anti-Corruption Charter took place at the international scientific and practical conference “Cooperation of State and Business against Corruption” organised by the RF Chamber of Commerce, United Nations Office on Drugs and Crime and International Anti- Corruption Academy.
The Anti-Corruption Charter of the Russian Business provides that an anti-corruption programme and other measures of anti-corruption and corporate policies targeted to protect interests of entrepreneurs, and fair and open business shall be introduced into corporate governance practices. Jointing the Anti-Corruption Charter requires from its members that their compliance with Charter principles shall be acknowledged by the public.
Personnel professional development G4-SO4 Nowadays the anti-corruption legislation and practices are developing rapidly. The staff of the Department for Operational Control and Compliance (DOC&C) refresh and upgrade their professional knowledge and skills on a regular basis. Due to the high level of professionalism, the Department management team became the members of the Anti-Corruption Expert Council of the Chamber of Commerce and Industry of the Russian Federation. G4-16 In 2015, the DOC&C staff received the following training:
  • corporate compliance with the Russian and international anti-corruption legislation;
  • compliance with the RF procurement legislation and its application practice;
  • internal audit and anti-fraud measures (to improve professional knowledge and skills of the staff involved in Federal Grid Company’s financial and business audits).
  • set-up of the compliance control and corruption risks management system;
  • control and risk management;
  • implementation of the corporate anti-corruption policy as the complex of interrelated principles, procedures and actions targeted to prevent corruption-related offences in the company’s operations.
  • set-up of the compliance control and compliance risk management system.
A number of training videoconferences on anti-corruption activities and transparency of the Company’s business were conducted for the staff of the Company’s Executive office and branches.
Evaluation of the Anti- Corruption policy effectiveness G4-SO4 To review the corruption perception in Federal Grid, personnel awareness of the Company’s Anti-Corruption Policy as well as to evaluate the policy effectiveness and improve anti-corruption activities in Federal Grid Company the employee survey was conducted. According to the survey results, the number of employees who evaluate the Company’s Anti-Corruption Policy as effective increased by 3% for the Company on the whole, while the number of employees willing to report on acts of corruption by 2% (in the Executive Office – by 7%). The personnel awareness of whom to contact if they become aware of some acts facts of corruption increased by 9%.
Anti-corruption control To implement the RF Government instructions regarding the transparency of financial and business operations of the Company and its branches monthly reports on signed contracts, including the chain of owners of counterparties, were submitted to the Russian Ministry of Energy, the Federal Financial Monitoring Service (Rosfinmonitoring) and the Federal Tax Service of Russia.

Anti-Corruption Management System

Corruption Risk Management

To exercise a risk-based approach to the implementation of the Anti-Corruption Policy in Federal Grid Company, Federal Grid’s Corruption Risk Map and Corruption Risks and Anti-Corruption Control Procedures Matrix have been developed G4-SO3

Corruption risks are management based on the single integrated approach to the measures targeted to implement one of Company’s strategic development goals – corruption prevention and management.

To minimise corruption risks the following control procedures were enacted in 2015:

 

Control procedures in respect of corruption risks in procurement G4-SO3:   Anti-corruption review of sets of documents for 13,846 transactions (and procurement procedures), G4-SO9 including:
  • Documents for 11,215 transactions received from potential counterparties (participants of procurement procedures) were reviewed, out of them documents for 3,140 transactions were not approved or sent back for revision;
  • Documents for 2,631 transactions received for the Central Tender Commission and Permanent Tender Commission were reviewed, out of them documents for 289 transactions were not approved or sent back for revision.
The due diligence review found the following violations:
  • failure to comply with the requirement to inform on the chain of counteragent owners including ultimate beneficiaries;
  • l and plot overpricing in land legal relations for the construction of Company’s energy facilities;
  • non-submission of a full set of documents.
Control procedures in respect of corruption risks in charity G4-SO3. The due diligence review of charity-related documents as well as the audit of funds allocated to 55 organisations and totaling more than RUB 48million.
Control procedures in respect of corruption risks related to abuse of powerG4-SO3.    The anti-corruption review of 6,325 regulatory and administrative documents and their drafts in the Company’s Executive Office and branches were conducted; The conflict of interest was declared by the management team of Federal Grid Company with the follow-up check of more than 5 thousand declarations as well as identification of conflicts of interest, settlement of pre-conflict situations and resolution of conflicts of interest. G4-41. The information on income, property and liabilities of the persons applying for top management vacancies and top managers as well as their family members was collected and reviewed.
Control procedures in respect of corruption risks during contract signing and implementation of contractual obligations. G4-SO3.   Monitoring of transactions for conflicts of interest, timely receipt of information about changes in the chain of counterparty owners, as well as the inclusion of an anticorruption clause and other mandatory conditions in contracts . G4-41 Control of security (in the form of bank guarantees) of counterparty obligations under concluded contracts:
  • More than 1,209 bank guarantees for more than RUB 40billion were checked. Three counterfeit bank guarantees for the total amount of RUB 12 million were found.
  • Company’s demands for payment under bank guarantees were monitored.
    Due to the failure of counterparties to perform their contractual obligations in 2015 Federal Grid issued 293 demands for payment for the total amount exceeding RUB22.5 billion.
Control procedures in respect of corruption risks during contract signing and implementation of contractual obligations. G4-SO3. Monitoring of the compliance with the Regulation on exchange of business gifts and reporting by employees of Federal Grid’s Executive Office on receipt of gifts in connection with their official capacity or implementation of their official duties, on handover and evaluation of gifts, their sale/purchase and booking of their proceeds.

2016 Plans

  • review and improve Federal Grid’s anti-corruption regulations in line with anti-corruption law amendments of 2015;
  • perform a set of measures to settle the conflict of interest in the Company including the declaration of the conflict of interest with consideration of the amendments of Federal Anti-Corruption Law No. 273-FZ dated 25 December 2008 that were adopted in 2015;
  • implement measures to manage corporate corruption risks taking into account the Methodic Guidelines for arrangement of anti-corruption risk management and internal control in joint stock companies with participation of the Russian Federation and approved by the Resolution of the Federal Agency for State Property Management (Rosimuschestvo) No. 80 dated 2 March 2016;
  • carry out regular organisational, awarenessbuilding and other measures to ensure that Federal Grid’s employees comply with the anti-corruption regulations.

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