Anti-corruption
Russian Railways’ anti-corruption policy Russian Railways’ Order No. 472r dated 24 February 2015 (as amended by Russian Railways’ Order No. 2277r dated 8 November 2017). is a set of interrelated principles and procedures designed to prevent and combat corruption and minimise corruption risks. It also enables the Company to achieve its sustainability goals.
Russian Railways’ anti-corruption policy outlines the following priorities:
- to ensure that the Company’s employees, directors and stakeholders have a uniform understanding of the zero tolerance approach to corruption in all its forms and manifestations;
- to communicate the importance of publicly declaring zero tolerance for corruption and bribery in business;
- maintain compliance with the Russian anti-corruption laws.
Russian Railways’ anti-corruption policy is underpinned by the following principles:
- the Company declares zero tolerance for corruption and is committed to compliance with Russian laws, international treaties signed by Russia and generally accepted standards;
- the Company takes a systematic approach to assessing corruption risks as a way to form an adequate response to corruption;
- the Company regularly monitors the effectiveness of its anti-corruption practices;
- the Company exercises due diligence in all its activities and managerial decision-making;
- the Company’s employees receive regular training in anti-corruption.
Preventive measures are based on the following two components:
- implementing anti-corruption standards that establish responsibilities, limitations and bans integrated into employment contracts;
- ensuring compliance by employees and management at all levels.
In accordance with the law, the Company’s employees may be subject to disciplinary, administrative and criminal liability for committing corruption offences.
The incidents when the Company was subject to administrative liability were caused by non-compliance with applicable restrictions in employment of former government and municipal officials. Entities hiring former officials are required to report signing respective employment (civil law) contract to the official’s last known employer. Notification to that effect must be sent within ten days after respective contract is signed.
To prevent violations in this area, Russian Railways implements a number of measures. Letters with clarifications are sent to heads of units. The Company distributes visual aids describing an algorithm of what must be done when hiring former government and municipal officials. A respective notification form was added to the Human Resource UCAS Human Resource Uniform Corporate Automated System. , with the system also displaying a pop-up window to remind the user to send the notification to the new hire’s previous employer.
The principle of zero tolerance for corruption set out in Russian Railways’ anti-corruption policy prohibits Russian Railways’ directors, employees and counterparties, acting directly or through third parties, from engaging, or inducing anyone to engage in corruption, whatever the business practices are in any particular country.
