Corruption risk management

Russian Railways’ corruption risk management is an integral part of the Company’s risk management and internal control system. We streamline and harmonise risk management approaches in line with the Guidelines for Corruption Risk Management Approved by Russian Railways’ Order No. 192/r dated 1 February 2021. , Risk Management and Internal Control Policy Approved by the Company’s Board of Directors (Minutes No. 17 dated 27 May 2019) and enforced by Russian Railways’ Order No. 1223/r dated 18 June 2019. and other documents.

Across the Company’s business units, employees responsible for anti-corruption practices at all governance levels perform regular and consistent assessment of corruption risks, exercise multi-tier control and take corrective actions.

In 2022, the units performed an annual assessment of corruption risks, with the registers for the year compiled after such assessment, response plans implemented and the Russian Railways’ consolidated register of corruption risks updated.

We also perform an annual internal audit to check the RMICS performance in preventing and combatting corruption.

The Code of Ethics for Internal Auditors Russian Railways’ Order No. 3034/r dated 25 December 2019. establishes:

  • main ethical norms and rules, including the objectivity principle and the ‘no conflict of interest’ principle;
  • unified mandatory rules of conduct for internal auditors.

The Board of Directors’ Audit and Risk Committee is regularly informed on monitoring outcomes for RMICS as regards anti-corruption performance and the effectiveness of relevant measures.

We conduct due diligence on companies intending to enter into contracts with Russian Railways, including bidders competing in a tender or auction for a contract to supply goods, work or services for Russian Railways’ needs.

To sign a contract with Russian Railways, counterparties must submit, among other documents, a beneficial owner certification form as provided for in the contract. All draft contracts require approval of the Security Department that can be granted after the successful completion of a security audit.

Contracts with counterparties also include anti-corruption clauses stipulating the following:

  • guaranteed compliance with the relevant regulations;
  • termination of the contract if the counterparty is found to engage in corruption.

In 2022, Russian Railways fully implemented the anti-corruption action plan for the reporting period, focusing on managing corruption risks and conflicts of interest and making its educational, awareness raising and other anti-corruption initiatives more efficient.

Compliance monitoring and control are key elements of anti-corruption practices. Russian Railways’ business units and subsidiaries conducted over 110 audits of its regional and structural units, with follow-up corrective measures developed and put into action.