Address from the General Director of Zarubezhneft JSC S.I. Kudryashov
Corruption prevention is an integral part of the company’s activities and its culture — both in relations with the partners and private entities and the governmental authorities.
The company has developed its own anti-corruption policy and regularly undergoes the procedure for confirmation of the anti-corruption measures implementation. In 2017 we conducted an independent anti-corruption audit which has identified several areas for improvement, and the training course for the employees has been developed under its results.
The program of this training is based on the best international practices in the area of corruption prevention system development, up-to-date international studies, observation of the auditor and is customized for our company with account of the industry peculiarities. The target audience of the training events conducted in the Company are all employees of Zarubezhneft JSC including top management.
The anti-corruption clauses have been integrated into the contracts and agreements with the partners and contractors, labor contracts with the employees of Zarubezhneft JSC, contracts on material remuneration of the Russian employees working abroad as well as the number of regulatory documents regulating the business processes associated with high corruption risk.
The Compliance committee of Zarubezhneft Group of Companies has been operating since 2017, its purpose is review of the issues associated with the corruption prevention, ensuring protection of rights and legal interests of the employees, the state and the Company.
A security hotline is operating in the Company. The Company guarantees protection to the employee who has reported the violation of the Corporate ethics code, including corrupt violations. We have commences the implementation of the third stage of the corporate development strategy which contemplates entering new assets in the framework of the developed competences. Suspicion of the ethical standards violation by only one employee may significantly affect the new project. I’d like to note that corruption is a problem where there are no persons on the «right» side. Both the one who is bribing and the one who is bribed bear the responsibility.
Considering that we carry out activities in different jurisdictions, we need to account for the local and international laws for corruption prevention and not turn blind eye to the associated risks. Presence of risk is a usual thing, it is the indicator of the company’s moving forward and operating. However, only through knowing and assessing these risks in timely manner we would be able to take proper measures to protect our employees, company and, ultimately, the state. The reputation with the foreign colleagues is not less important than the reputation within the home country.
I encourage the employees to inform of the conflict of interests, bribery and corruption. On my part as the head of the company I promise that in my actions and decisions I shall keep up to the same principles which I expect our employees to keep up to!
Statement of Zarubezhneft JSC
Complying with the requirements of the Russian law and the laws of other countries where the Company carries out or plans to carry out its activities, longing to comply with the best international practices, business conduct culture, ethical and other professional standards, Zarubezhneft JSC pays significant attention to the corruption prevention activities.
A whole range of developed and regularly updated internal regulatory documents aimed at corruption prevention as well as other documents containing anti-corruption provisions are currently operating in the company. The requirements of these documents are communicated to all the employees of the Company.
The anti-corruption clauses have been integrated into the contracts and agreements with the partners and contractors, labor contracts with the employees of Zarubezhneft JSC, contracts on material remuneration of the Russian employees working abroad as well as the number of regulatory documents regulating such business processes as procurement and investment activities, M&A transactions, charity and sponsorship, personnel management.
Training of employees
The Company implements multi-profile and consecutive measures to prevent, eliminate (minimize) the causes and conditions giving way to corruption, to develop the anti-corruption awareness of the employees characterized by intolerance to any forms of corruption.
In order to fulfil this task we have introduced a system of induction and regular training of employees. It is based on the best international practices in the area of corruption prevention system development, up-to-date international studies, observation of the auditor and is customized for our company with account of the industry peculiarities. The target audience of the training events conducted in the Company are all employees of Zarubezhneft JSC including top management.
In accordance with the Article 1 of the Federal law dated 25.12.2008 No. 273-ФЗ «On corruption prevention», the following actions are deemed to be corruption:
а) abuse of official position, giving bribe, taking bribe, abuse of power or authority, commercial tampering or any other illegal use of job position by any person contradicting the interests of the society and the state for the purpose of gaining benefits in the form of cash, valuables, other property or monetized services, other property rights for own benefit or for the benefit of third persons or illegal provision of such benefit for the indicated person by other persons;
b) performance of actions indicated in the sub-clause «a» on behalf or for the benefit of a legal entity.