Countering Corruption

Transneft’s activities to prevent and combat corruption in 2019 were performed in accordance with Federal Law No. 273-FZ On Combating Corruption dated 25 December 2008, the National Anti-Corruption Plan for 2018–2020 and Transneft’s Action Plan for Preventing and Countering Corruption for 2019 approved by resolution of the Management Board of Transneft. The 2019 Action Plan included continuous measures to prevent and combat corruption, activities to ensure execution of instructions issued by the Russian Government and additional measures to enhance the efficiency of combating corruption at Transneft in line with the guidelines received from the comprehensive assessment of the efficiency of anti-corruption activities performed in 2018.

In 2019, Transneft ensured that the employees holding the positions of the President, the First Vice President and Vice Presidents of Transneft, as well as candidates to fill these positions, submitted information on their income, expenses, assets and liabilities to the Government of the Russian Federation.

Coordination of measures to prevent and combat corruption at Transneft is the responsibility of Transneft’s Commission for Countering Corruption. The functions of the Commission include reviewing notifications concerning conflicts of interest received from employees and deciding on the method of resolving them.

Continuous work is conducted at Transneft to identify and resolve employees’ conflicts of interest. Additional anti-corruption measures were introduced as part of the efforts to enhance the efficiency of preventing and resolving conflicts of interest in the activities of Transneft Group’s employees. These measures included submitting annual declarations on conflicts of interest.

The procedure for submitting the declarations on conflicts of interest and the list of positions subject thereto are determined by a Transneft order. The list includes positions implying a higher corruption risk due to organisational, administrative, audit and control duties, as well as positions within the key business units involved in contractual arrangements.

The work of Transneft’s anti-corruption hotline was organised for prompt response to notifications of corruption acts presumably committed by employees of Transneft Group.

In 2019, 403 employees of Transneft and 317 employees of Transneft subsidiaries were trained in anti-corruption programmes.

A memo on the basics of anti-corruption behaviour was brought to the attention of all employees. It describes the requirements of Transneft’s internal regulations governing the issues of preventing and combatting corruption, including prohibitions, duties and guarantees established for employees. The memo is currently available on the internal corporate portal.

Transneft’s employees are familiarised with the internal regulatory documents specifying the anti-corruption measures on an annual basis.

Results for the Reporting Year

In accordance with the Action Plan, the internal regulatory documents specifying measures for preventing and combating corruption were updated in 2019, including the Regulations on the Anti-Corruption Commission of Transneft, the Regulations on the Procedure for Provision of Charitable Assistance by Transneft and Transneft subsidiaries, as well as the Sponsorship Procedures.

In 2019, the standard Regulations on Conflicts of Interest for Transneft Subsidiaries were developed and approved to ensure a unified approach for resolving conflicts of interest in the activities of the Group’s employees.

In pursuance of the National Anti-Corruption Plan for 2018–2020, Transneft organised advanced training for employees involved in implementation of anti-corruption measures, as well as training for employees of the Group holding positions included in the corruption risk prevention lists.

In 2019, the Register of Corruption and Bribing Risks was updated in order to determine which of Transneft’s business activities had a higher corruption risk. A target workflow of business processes for corruption risk management was approved in order to increase the efficiency of anti-corruption measures in the business areas with a higher corruption risk. The workflow specifies the main stages of work and their sequence and will serve as the basis, on which an internal regulatory document will be developed to establish a procedure for working with corruption risks, as well as to regulate the process and method for their assessment.

In 2019, a standard anti-corruption provision was introduced to the standard contract templates of Transneft in order to prevent corruption offences in interaction with counterparties.

Reports on the implementation of annual plans of anti-corruption activities and on the implemented anti-corruption measures are considered by the Management Board of Transneft and the Board of Directors of Transneft.