PJSC NCSP’s efforts to combat corruption comply fully with current Russian legislation. The Company’s employees conform to Federal Law No. 273-FZ, dated December 25, 2008, on Combating Corruption; Russian presidential Order No. 309, dated April 2, 2013, on Measures to Implement Certain Provisions of the Federal Law on Combating Corruption; and the Methodological Recommendations for Development and Adoption of Organizational Measures to Prevent and Combat Corruption approved by the Labor and Social Security Ministry of Russia on November 9, 2013.
PJSC NCSP approved an Anti-corruption Policy to Counter Involvement in Corrupt Practices in January 2015. The main goals of this policy are to:
- Minimize the risk of the Company, its management and employees becoming involved in corrupt practices
- Instill a common understanding of the policy of zero tolerance for corruption in all forms and manifestations in Company employees, regardless of their position, as well as business partners and other parties
- Summarize and clarify the main requirements of Russian legislation against corruption applied at the Company
PJSC NCSP is implementing a plan of action aimed at preventing corrupt practices that includes procedures for reporting signs of corruption, responding to red flags and making the Company’s counterparties aware of the requirements of the anti-corruption policy.
In 2015, PJSC NCSP approved a Code of Ethics and Conduct for employees, and drafted and approved a Regulation governing the procedure for employees to report situations if they are induced to commit corruption violations, cases of other company employees committing corruption violations and cases of conflicts of interest. These documents apply to all PJSC NCSP employees, regardless of their position, the duration of their employment and the nature of their work.