Rosseti and its S&As’ Anti-Corruption Policy sets forth a consistent approach to compliance with Clause 13.3 of Federal Law No. 273-FZ dated 25 December 2008 On Combating Corruption in Part that Concerns the Company’s Obligations to Develop and Put in Place Measures to Prevent and Combat Corruption, including:
Identification and further elimination of causes of corruption (anti-corruption)
Identification, prevention and suppression of corruption and sundry offences
Minimisation and (or) liquidation of the consequences of corruption and sundry offences
In the reporting year, the Anti-Corruption Plan for 2022 was approved by Order of Rosseti Kuban No. 73-od dated 9 February 2022.
In 2022, the following was done to promote the Company’s Anti-Corruption Policy.
Anti-corruption policy aspect
Measures taken in 2022
Establishment of the inner control and risk management process to prevent and combat corruption
Reports on the results of anti-corruption monitoring for 2021 and the first six months of 2022 were prepared and forwarded to the Management Board, the Audit Committee and further to the Board of Directors of the Company for review. The reports were reviewed and taken into account by the Audit Committee and the Board of Directors of the Company without any comment.
The 2nd line of defence report for 2021, along with the results of self-assessment of control procedures efficiency as of the end of 2021 and quarterly updated passports of functional risks, business process risks, and Progress report on the Risk Management Action Plan for the Anti-corruption sub-process were prepared and forwarded to the Company’s management
Identification and clearing of conflict of interests
During annual declaration of conflicts of interest of employees for 2021, 2,255 declarations were collected and 5 pre-conflict situations in the Company’s branches were identified.
By the end of 2022, all pre-conflict situations were resolved.
Rosseti Kuban Corporate Ethics Compliance and Conflict of Interest Commission had two meetings.
They reviewed the submitted statements of income, property and property liabilities born by the top managers or their immediate family members in 2021. As a result, no signs of affiliation, conflict of interest, or pre-conflict cases were identified.
Conflicts of interests were declared for candidates for vacant positions at the Company. In 2022, 173 opinions were issued on the screening of candidates applying for vacant positions at Rosseti Kuban, 43 of which were negative
Development and introduction of standards and procedures to ensure good practice
In 2022, agreements on compliance with the requirements of the Anti-Corruption Policy and the Code of Corporate Ethics and Conduct of Employees were obtained from 86 new hires of the Company.
The Company developed and effected six organisational decrees on anti-corruption compliance and the implementation of its Anti-Corruption Policy
Review and verification of reports of possible corruption and sundry abuses
In 2022, the Company received 11 reports of possible corruption and other abuses via the feedback form in the Anti-Corruption Policy section of Rosseti Kuban’s website.
The Company carefully looked into every such report. None of the reported cases was confirmed
Anti-corruption measures in interaction with partners and subcontractors
Information about signed agreements, additional agreements, and new subcontractors or business partners was added on a daily basis to the Company’s automated system for collection and analysis of beneficiary data; in 2022, more than 69,000 agreements and additional agreements were uploaded there.
The procurement documentation underwent the approval procedure. In 2022, the Company participated in 821 procurement procedures, reduced the initial (maximum) price in 101 procurement procedures for the total amount of RUB 17.78 million, and cancelled two procurement procedures for RUB 23.63 million.
More than 6,600 agreements submitted for procurement procedures include an anti-corruption clause and a beneficiary disclosure obligation for the counterparty
Joint corporate efforts to prevent and combat corruption
The Company participated in the Knowledge Day organised by Rosseti Group on implementing the instructions of the President of the Russian Federation on the National Anti-Corruption Plan for 2021–2024 in Rosseti Group and its S&As. Innovations in Russian anti-corruption legislation
Combating bribery of foreign public officials and officials of public international organisations
The Company received no reports on bribery of foreign public officials and officials of public international organisations from representatives of state authorities and law enforcement bodies of the Russian Federation, international and other organisations in 2022
Legal education and development of law-abiding behaviour, counselling and training for employees
The Company continuously updates its legal framework and takes all the necessary measures and anti-corruption procedures to instill zero tolerance to corruption in its employees.
Over 2022, 804 employees of the Executive Office and branches of Rosseti Kuban underwent training under a programme on preventing and combating corruption.
The Company modified its Territory without Corruption stand to increase the efficacy of awareness, education, and other initiatives designed to combat corruption.
Along with the representatives of the Security Department of Rosseti, the representatives of the Company participated in the meetings of the working group, in the meeting of Rosseti Central Commission on Compliance with Corporate Ethics and Conflict of Interest Resolution, in the end-of-year meeting
For 2023, the Company scheduled to approve and pun in place its Annual Anti-Corruption Plan and to enhance the following mechanisms:
Identification and clearing of conflict of interests
Compliance with anti-corruption procurement standards
Prevention of corruption in interaction with partners and subcontractors
