Anti-corruption security at KSC LLC is maintained in accordance with the Anti-Corruption Policy approved by Order No. KSC-0033/OD of the General Director of KSC LLC dated 27 March 2019; it is part of the Compliance Policy approved by Order No. KSC-0057/OD of the General Director of KSC LLC dated 15 May 2019.
Regulations on the Adoption of Measures to Prevent Corruption at KSC LLC, Its Managed and Controlled Companies
Compliance Policy
The Anti-Corruption Policy of KSC LLC was adopted on the basis of / for pursuance of the following documents:
- applicable laws of the Russian Federation — The Constitution of the Russian Federation (Articles 37, 39), Labour Code of the Russian Federation No. 197-FZ dated 30 December 2001 (Articles 81, 137, 138, 142, 192), Criminal Code of the Russian Federation No. 63 dated 13 June 1996 (Articles 158-160, 174, 175, 183, 289, 291, 201, 201.1, 204-204.2, 304), Administrative Offences Code of the Russian Federation No. 195-FZ dated 30 December 2001 (Articles 19.28, 19.29), Labour Code of the Russian Federation (Articles 448, 449, 575, 1064-1070, 1102-1109), Federal Law No. 273-FZ dated 25 December 2008 , Counter-Acting Corruption (Article 13.3), Federal Law No. 14-FZ dated 8 February 1998, On Limited Liability Companies (Articles 32, 47), Federal Law No. 172-FZ dated 17 July 2009, Anti-Corruption Expert Review of the Laws and Regulations, Draft Laws and Regulations, National Anti-Corruption Plans approved by the Decrees of the President of the Russian Federation;
- ratified international legal acts in the field of anti-corruption — the UN Convention Against Corruption (adopted by the UN General Assembly on 31 October 2003, ratified by the Russian Federation in 2006), the Council of Europe Convention on Criminal Liability for Corruption dated 27 January 1999 (ratified in 2006), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions dated 17 December 1997 (ratified in 2012), the United Nations Convention Against Transnational Organized Crime dated 15 November 2000 (ratified in 2004), the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (Warsaw Convention) dated 16 May 2005 (ratified in 2017).
- recommendations of the authorities of the Russian Federation — Methodological recommendations of the Ministry of Labour of the Russian Federation dated 8 November 2013 and 1 October 2019 on the development and adoption of organizational measures to prevent and counteract corruption, Methodological recommendations of the Ministry of Labour of the Russian Federation dated 19 September 2019 on the procedure for assessing corruption risks in an organization;
- recommendations of international and national organizations — ISO 19600:2014 Compliance Management Systems. Guidance, ISO 37001: 2016 Anti-Bribery Management Systems — Requirements with Guidance for Use, recommendations of the National Compliance Association (CMS 2015 RU NAC Compliance System and CMS AC 2015 RU NAC Anti-Corruption Compliance), the Anti-Corruption Charter of the Russian Business.
The main objective of combating corruption at KSC LLC is to eliminate the causes and conditions of corruption-causing and corruption factors.
In order to achieve this objective, KSC LLC implements a variety of anti-corruption measures:
In relations with a subcontractor:
- step-by-step verification of a subcontractor for reliability in terms of the purity of their operations, reputation and non-involvement in corruption activities using special information systems;
- inclusion of an anti-corruption clause in all executed contracts to represent the mutual obligations of KSC LLC and a subcontractor and the liability for their non-compliance. (Order No. KSC-0070/OD of the General Director of KSC LLC, Approval of the Sections “Representations and Warranties about the Circumstances” and “Anti-Corruption Clause” when Entering into Contracts);
- inclusion of additional anti-corruption clauses in the standard contract templates, and in the enterprise electronic document management system when launching the contract for internal approval.
In a relationship with an employee:
- inclusion of requirements for compliance with the anti-corruption policy at KSC LLC in the employment contracts;
- conducting a compliance briefing that covers anti-corruption issues;
- anti-corruption verification of candidates for employment (transfer) to corruption-prone positions;
- training courses for employees on anti-corruption issues at KSC LLC, as well as on the issues related to their specialization, within the framework of annual training programs, with an assessment of knowledge of employees when calculating KPIs;
- management and declaration of a conflict of interest with the involvement of the Ethics Commission as a procedure for establishing facts and circumstances that cause personal interest, conflict of interest, or eliminating favourable conditions for committing corruption-related offenses (02 STO “Conflict of Interest Management in KSC LLC, Managed and Controlled Companies”, approved by Order No. KSC-0236/OD of the General Director of KSC LLC dated 08 December 2020)
In relations with the authorities:
- obligation to inform about violations of the anti-corruption laws of the Russian Federation, which became known by the CC KSC;
- assistance in conducting verification and other measures by the authorities within the framework of the applicable laws;
- organization of employees training in interaction with the authorities;
- conducting audits of KSC Group of Companies in order to prevent violations;
- prevention of interference of employees and representatives of the KSC Group of Companies in the performance of official duties by officials of judicial or law enforcement authorities.
In order to counter corruption, KSC LLC uses the resource Compliance Helpline, which allows anyone to report any violations related to the business processes of KSC LLC.
Access to the Compliance Helpline is provided:
- in the official website of KSC LLC via the Compliance Helpline button, along with the completion of the proposed application form;
- by email hotline@kscgroup.ru;
- using messengers (WhatsApp, Viber, Telegram) linked to the phone +7 963 990 17 03.
When making an application, the applicant needs to account for the following requirements:
- a detailed description of the essence of the appeal, indicating the persons involved (full name, position, division) and the specific actions that led to the violation;
- contact details of the applicant (phone, e-mail);
- the information shall be reliable.
The following is guaranteed to an applicant:
- feedback if the contact details are indicated by an applicant;
- confidentiality of information.
If the application contains information about a possible or committed illegal act, the applications are transferred to the law enforcement authorities.
Contacts of the anti-corruption division of KSC LLC: +7 495 788 19 50 (ext. 53-85, 53-88, and 53-82).
