Ethics and anti-corruption activities

Since February 2014, the Gazprom Neft Group has employed an Anti-Corruption and Anti-Fraud Policy with which all current employees of the Company and its subsidiaries are familiar. It is based on Russian legislation, the Code of Corporate Governance and other internal regulatory acts. The Policy describes the main requirements for implementing business processes in order to mitigate corruption risks and also prescribes anti-corruption rules and standards for all the Company’s employees.

Gazprom Neft has a risk management system for corruption that includes the following anti-corruption measures at all levels of internal corporate regulation:

  • contracts concluded with contractors include anti-fraud and anti-corruption obligations;
  • the Company regularly conducts an assessment of corruption-related risks. Measures to identify and prevent corruption and fraud risks have been included in the Company’s risk management system;
  • Gazprom Neft has a hotline that it uses as a system to collect and process information about fraudulent actions, administrative violations and violations of industrial safety requirements. The goal of the hotline is to provide any individual with an opportunity to report violations at Gazprom as well as its subsidiaries. All the reports received are processed with the highest level of confidentiality. The information is verified in compliance with the requirements for objectivity and independence by individuals who are not parties to the proceedings in question;
  • official investigations are conducted based on any violations that are identified and the guilty parties are held accountable.

The Company has zero tolerance for possible risks of corruption and fraud. Working to prevent such risks remains one of the top priorities in the activities of Gazprom Neft management and employees.

Combating Fraud and Corruption
As part of its programme to minimise corruption risks in 2016, the Company developed the online course ‘Combating Fraud and Corruption at Gazprom Neft PJSC’, which addresses aspects of anti-corruption behaviour among employees when performing their official duties. This course was recommended for all current Company employees and mandatory for all newly hired employees.