Security and anti-corruption

Anti-corruption policy

Pursuant to the OAO IDGC of Urals FY2017 Anti-corruption Program, the Company’s Anti-corruption Compliance Procedures unit:

• has conducted two declaration campaigns:
  • declaration campaign on directors’ property, income and property-related obligations (65 filers and 274 filers’ relatives underwent scrutiny). The scrutiny exposed 1 potential conflict of interests that was examined by the Company’s panel, liable for compliance with corporate ethics norms and settlement of conflicts of interest.
  • annual declaration campaign on 2016 employees’ competing interests (3,407 employees checked, incl. 294 employees checked by the AC AISS module). 9 pre-conflict situations were exposed, examined and settled by the Company’s panel.
• has implemented commitment-enforcing standards and procedures into Company’s practices:
  • revision of the Company’s regulations on combat against corruption, Anticorruption Policy of PAO Rosseti and its SACs^[88], Settlement of Conflicts of Interests^[89], Corporate Ethics and On-duty Conduct Code^[90], its visualized version^[91];
  • OAO IDGC of Urals has confirmed its compliance with the Anticorruption Charter by filing a declaration with the Russia’s Chamber of Commerce and Industry on 05.06.2017, as a part of monitoring of the progress in anti-corruption activities by representatives of public organizations with charter objectives stating participation in anti-corruption activities, pursuant to the regulations on the register of the Charter participants;
  • arrangement of inclusion of anti-corruption additional agreements into employees’ labor contracts (15,318 additional agreements concluded).
• has exposed and settled conflicts of interests:
  • 102 nominees checked (incl. 46 cases of personnel reshuffling), 2 nominees were rejected due to unsettled pre-conflict situation;
  • 3 meetings of the Company’s panel, liable for compliance with corporate ethics norms and settlement of conflicts of interest.

During the reported period 269 employees underwent anti-corruption trainings.

Pursuant to the decree^[92] a representative of the Company’s Anti-corruption Compliance Procedures unit has attended 7 meetings of the work group dealing with improvement of anti-corruption methodology support.

The unit’s anti-corruption hotline received 2 whistleblowing reports but no substantiation of the reported facts was discovered. 1,926 contractors were scrutinized in terms of disclosures related to the ownership chain and ultimate beneficiaries and were input into the AC AISS. The total number of contractors in the AC AISS is 21,249.

Security of operations.

Audits of financial and economic operations revealed 30 cases of abuse, improper execution of duties and other misconduct of the employees during 2017. As a result, 59 employees were brought to disciplinary responsibility, 3 employees were dismissed and bonuses for 25 employees were deducted. We handed over 2 criminal complaints on 2 legal entities to the law enforcements that were dismissed afterwards, police orders to dismiss criminal complaints being challenged.

To enforce economic resilience of tenders and contracts we have checked 14,392 legal entities and individuals, 92 adverse opinions prepared. During the reported period we examined 1,635 nominees (potential employees or employees being transferred to other positions), 181 adverse opinions prepared.

We handed over 159 reports with facts of economic damage (115 inventory thefts, 30 cases of unmetered electricity consumption, 6 cases of overdue receivables, 8 other offences) to the law enforcements for inspections, stated by Article 144 of the Russian Federal Code of Criminal Procedure. As a result, 79 criminal cases related to inventory thefts and 2 criminal cases related to unmetered electricity consumption were launched. 8 persons who stole our property from grid facilities were prosecuted.

As for administrative proceedings, 660 offenders were held administratively liable: 599 persons for unmetered electricity consumption and 61 persons for other administrative offences.