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2019 Interactive Sustainability Report

Anti-corruption policy

Corporate Fraud and Corruption Policy

We are convinced that one of the most important conditions for sustainable business development is the availability of measures to combat corporate fraud and corruption, strict compliance with the requirements of the anti-corruption legislation of the Russian Federation, as well as any country in which the Company operates.

The company adheres to generally accepted international standards in the field of combating corruption and a complete rejection of corruption in any form and manifestation in its activities.

In accordance with the Convention of the Council of Europe "On Criminal Responsibility for Corruption", Federal Law No. 273-FZ of 25.12.2008 "On Combating Corruption", the Decree of the President of the Russian Federation "On the National Anti-Corruption Plan for 2018-2020" and the Standard "Anti-Corruption policy of PJSC TATNEFT named after V. D. Shashin "The company strictly complies with the anti-corruption legislation of the Russian Federation, as well as the anti-corruption legislation of other countries in whose territory it operates. 

The Company's position in the field of anti-corruption is public

Securing responsibility for the implementation of the Company's anti-corruption policy

Responsibility for the implementation of the Company's anti-corruption policy is assigned to the Department of Economic Security, Information Protection of Civil Defense and Emergencies, Legal Department, Internal Audit Department, Control and Auditing Department, HR Department, Personnel Audit Service. In the organizations of the Tatneft Group - on the heads of the organizations of the Tatneft Group.

Regulatory framework for anti-corruption policy
  • Federal Law of the Russian Federation of December 25, 2008 No. 273-FL "On Combating Corruption";
  • Decree of the President of the Russian Federation of June 29, 2018 No. 378 "On the National Anti-Corruption Plan for 2018-2020";
  • Criminal Code of the Russian Federation of 13.06.1996 No. 63-FL;
  • Code of the Russian Federation on Administrative Offenses dated 30.12.2001 No. 195-FL;
  • Labor Code of the Russian Federation of December 30, 2001 No. 197-FL;
  • Guidelines for organizing risk management and internal control in the field of preventing and combating corruption in joint-stock companies, approved by order of the Federal Property Management Agency No. 80 dated 02.03.2016;
  • Methodological recommendations of the Ministry of Labor of Russia on the development and adoption by organizations of measures to prevent and combat corruption in pursuance of subparagraph "b" of paragraph 25 of the Decree of the President of the Russian Federation of April 2, 2013 No. 309 "On measures to implement certain provisions of the Federal Law" On Combating Corruption " and in accordance with Article 13.3 of the Federal Law of December 25, 2008 No. 273-FL "On Combating Corruption";
  • Corporate Governance Code recommended by the letter of the Bank of Russia dated April 10, 2014 No. 06-52 / 2463.
Internal documents regulating the Company's practice in the field of combating corporate fraud and corruption
  • Anti-corruption policy adopted by the Board of Directors of PJSC TATNEFT;
  • Organization Standard of the Anti-Corruption Policy of PJSC TATNEFT named after V. D. Shashina;
  • Regulations on the settlement of conflicts of interest in PJSC TATNEFT named after V. D. Shashina;
  • Regulation on the acceptance and donation of gifts at PJSC TATNEFT named after V. D. Shashina;
  • Regulation on compliance with anti-corruption norms and rules in the process of fulfilling contractual obligations;
  • Regulations for the functioning of the corporate system "Hot Line";
  • Code of corporate culture for employees of PJSC TATNEFT;
  • Regulations for checking suppliers of goods, works and services according to the criteria of economic security;
  • Regulations on the organization of contractual work in PJSC TATNEFT named after V.D.Shashina. 

Review progress

In 2019 and 2020 the Company carried out work to develop the practice of combating corporate fraud and corruption and to ensure that corporate practices are in line with the best international regulatory and methodological framework

The company strives to comply with and integrates into its activities the principles and mechanisms contained in the following international regulatory legal and methodological documents:

  • United Nations Convention against Corruption (adopted in New York on 31.10.2003 by Resolution 58/4 at the plenary meeting of the 58th session of the UN General Assembly);
  • Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, adopted by the Organization for Economic Cooperation and Development (OECD) on November 21, 1997;
  • Criminal Law Convention on Corruption (concluded in Strasbourg on 27.01.1999 ETS No. 173);
  • Code of Conduct to Prevent Extortion and Bribery of the International Chamber of Commerce (ICC Rules on Combating corruption);
  • Transparency International Anti-corruption Plain Language Guide 2010, Transparency International Anti-corruption Plain Language Guide.

We also follow the international standards of the ISO 37001.

Basic principles, rules and procedures aimed at preventing corruption

The rejection of corruption and the prohibition of corruption

The Company’s activities are based on the prevention of corruption in all forms and manifestations. All employees, members of the Company’s management bodies and other persons acting on behalf of the Company or in its interests are prohibited, directly or indirectly, personally or through some kind of mediation, to participate in corrupt activities regardless of the business practices in a particular country or region.

The inevitability of punishment

The company investigates all reasonably justified reports of violations of proper procedures to counter involvement in corrupt activities and prosecutes the perpetrators without regard to their position, duration of work, status in the Company and other relationships with it in accordance with applicable law and local regulations of the Company. The company makes all possible reasonable and legal efforts for the fastest possible suppression of violations. The company gives publicity to persons who have violated the requirements of the applicable law and the Anti-Corruption Policy.

Legality

In carrying out their activities, the company and its employees are obliged to comply with the norms of the Russian anti-corruption legislation, as well as the applicable norms of foreign anti-corruption legislation if they enter into legal relations that are subject to such legislation.

The tone of top management

Senior officials of the Company, including members of management bodies, heads of departments, divisions and other departments of the Company, must declare an uncompromising attitude towards all forms and manifestations of corruption at all levels, demonstrate, implement and observe it in practice.

Consistency and proportionality

The company develops and implements a system of proper procedures to counter and prevent involvement in corrupt activities. The company seeks to make the procedures as transparent, clear, achievable and reasonably consistent with the identified risks.

Due diligence principle

The Company monitors and checks counterparties and candidates for positions in the Company before making a decision to start or continue business relationships or recruitment for their reliability, rejection of corruption and the risk of conflict of interest.

Informing and learning

The company informs and explains the principles and norms of the applicable legislation, the Anti-Corruption Policy and other local regulatory documents in relation to countering involvement in corruption activities, including training employees in the basics of countering involvement in corruption activities and explaining its policy in this area to counterparties.

Monitoring

The company constantly monitors the implemented procedures to counter and prevent involvement in corruption activities and monitors their compliance. The Company periodically makes an independent assessment of the state of the system for countering involvement in corruption activities, as well as an assessment of the compliance of the Company’s activities with the applicable laws and the Anti-Corruption Policy. The results of the evaluation are reported to shareholders and the public in an annual report, press releases and other informational materials.

Improving the system of proper procedures

The company constantly monitors the implemented procedures to counter and prevent involvement in corruption activities and monitors their compliance. The Company periodically makes an independent assessment of the state of the system for countering involvement in corruption activities, as well as an assessment of the compliance of the Company’s activities with the applicable laws and the Anti-Corruption Policy. The results of the evaluation are reported to shareholders and the public in an annual report, press releases and other informational materials.

Reports of violations of the Anti-Corruption Policy can be transmitted in the following ways:

  • to your immediate or superior supervisor;
  • to the Company’s 24-hour hotline;
  • to law enforcement.
Protect the interests of workers

No sanctions can be applied to an employee for:

  • failure to engage in corrupt activities, even if as a result of such a refusal, the Company incurred losses, lost profits, and commercial and / or competitive advantages were not obtained;
  • bona fide reporting of alleged violations, acts of corruption, other abuses, or the lack of effectiveness of existing control procedures.

If an employee of the Company or another person provides knowingly false information or tries, using anti-corruption procedures, to obtain personal benefits contrary to the interests of the Company or applicable law, then such a person can be held liable in accordance with the current legislation and local regulatory documents of the Company.

A responsibility

Responsibility for the implementation of the anti-corruption policy of the Company and combating corruption in all areas of the Company’s activities is ensured by the Economic Security, Information Protection, Civil Defense and Emergency Situations Department of PJSC TATNEFT.

All employees, regardless of their position, are responsible, as provided for by the current legislation of the Russian Federation, for observing the principles and requirements of the Anti-Corruption Policy, as well as for the actions (inaction) of their subordinates who violate these principles and requirements. Persons guilty of violating the requirements of the Anti-Corruption Policy may be brought to disciplinary, administrative, civil or criminal liability on the initiative of the Company, law enforcement agencies or other persons in the manner and on the grounds provided for by the legislation of the Russian Federation, the Articles of Association of PJSC TATNEFT, local regulations and employment contracts.

Regular assessment of risks of involvement in corrupt activities

The company identifies, evaluates and periodically reevaluates the corruption risks characteristic of its potentially vulnerable business processes. When identifying and assessing risks, the Company takes into account the fullness of information about its activities and plans, including investment and strategic ones, available at the time of the assessment and reassessment.