Conflict of interest prevention and management

GRI 2-15

Prevention and resolution of conflicts of interest remain Russian Railways’ overarching priority in combatting corruption.

In 2022, the Board of Directors approved the Corporate Governance Code Minutes No. 1 dated 14 September 2022. featuring a dedicated anti-corruption section, which includes provisions on preventing and resolving conflicts of interest, among other things. They are mandatory for all governance bodies.

In 2022, to eliminate causes and conditions conducive to corruption, the Company approved a new version of the Regulation on Prevention and Resolution of Conflicts of Interest Russian Railways’ Order No. 1929/r dated 26 July 2022. . This document serves the following purposes:

setting out the timeline for reviewing conflict of interest reports;
explaining the meaning of a potential and actual conflict of interest;
listing those whose personal interest may lead to a conflict of interest;
describing the response procedure for employees in charge of reviewing such reports at business units and Russian Railways management;
stipulating criteria for determining a disciplinary action.

All the Company’s employees must do their best to prevent and resolve conflicts of interest.

In 2022, the number of conflict of interest disclosures at all corporate governance levels increased by 6% y-o-y to 2,676.

A total of 551 conflicts of interest were identified compared to 258 in 2021. The Company applied disciplinary actions for failure to comply with anti-corruption rules to 52 employees (23 employees were admonished, 23 employees were reprimanded, and 6 were dismissed).

Conflict of interest resolution at Russian Railways

As part of the efforts to identify and eliminate the causes and conditions for conflicts of interest and with a view to their timely and objective resolution, the Conflict of Interest Commission had a meeting on implementing corporate anti-corruption requirements and corruption restrictions.