Anti-corruption Policy of the Company

The Company began implementing anti-corruption policy in 2012. Measures for improvement of legal regulation of Company’s anti-corruption activity were held, a number of organizational and administrative documents were developed, the Policy of corruption and corporate fraud counteraction was approved.

In the next years the complex of measures for the conflict of interests management was implemented, the commission on observance of corporate ethics standards and a settlement of conflicting interests was created, the Code of Corporate Ethics was approved.

In 2014, the Company’s Board of Directors approved Anti-Corruption Policy of OJSC Rosseti and its S&A as the in-house document of the Company (Minutes No. 201/2014 of December 30, 2014) – the unified strategic document of PJSC Rosseti and its S&A determining a unified approach of Rosseti Group to implementation of requirements of Federal Law “On Corruption Counteraction” No. 273-FZ of December 25, 2008.

The full text of Anti-Corruption Policy is available on the Company’s web-site in the section About the Company / Constituent and in-house documents

PJSC Kubanenergo implemented the following measures on realization of Anti-Corruption Policy in the reporting year:

  • facts on 6 complaints about the possible facts of corruption of Company’s employees were checked;
  • conflicts of interests of 57 Company’s managers is declared and the declared data were checked, the facts of the conflict of interests were not determined;
  • inspection of declarations on property, income and property-related obligations of Company’s managers was carried out: 90 income statements of heads and 334 statements of their close relatives were checked;
  • procedures for contractors’ assessment, anti-corruption control of procurement activity were introduced;
  • starting from  October, 2015, all agreements with contractors include the Anti-Corruption Clause, i. e. the declaration on acceptance by the contractor of the Company’s Anti-Corruption Policy confirming contractor’s obligations to observe its requirements;
  • following the results of the year, information on disclosure of a chain of ownership of 8,535 contractors of the Company in accordance with Orders of the Government of the Russian Federation No. VP-P13-9308 of December 28, 2011 and No. VP-P24-1269 of March 5, 2012 is collected;
  • PJSC Kubanenergo joined to Anti-Corruption Charter of the Russian Business (Certificate No. 2319 issued by the Chamber of Commerce and Industry of the Russian Federation) on September 24, 2015.

According to Federal Law “On Counteraction to Illegal Use of Insider Information and Market Manipulation as well as on Amendments to Certain Legislative Acts of the Russian Federation” No. 224-FZ of July 27, 2010:

  • the list of insider information of PJSC Kubanenergo was determined;
  • The Company keeps the list of insiders and submits it to trade organizers, analyses transactions on securities market;
  • Find Information for insiders of the Company on the corporate web-site in section For Shareholders and Investors;
  • insider information confidentiality, and insider information handling procedures observance were ensured;
  • The Department of Anti-Corruption Compliance Procedures organized control of observance by the Company of legal requirements and subordinate legislation of the Russian Federation about insider information.

Improvement of the following mechanisms is planned for 2016 and subsequent years:

  • verification of information about a chain of ownership of contractors, including beneficiaries (as well as final ones);
  • on work with personal data when disclosing information on a chain of ownership of contractors;
  • anti-corruption standards of procurement activity;
  • systems of managing the conflict of interests.

The Company implements ethical standards of conducting honest business for improvement of corporate culture, observance of the best practices of corporate governance and maintenance of business reputation of the electric grid enterprises at an adequate level.