Comprehensive Program of Anti-Corruption Activities

In 2018, the Company rolled out a number of anti-corruption initiatives in accordance with the approved action plan for implementing the Comprehensive Program of Anti-Corruption Activities for 2018-2019.

Program workstreams What we did in 2018
Developing and updating the Company’s anti-corruption regulations and by-laws
  • Approval of a new Regulation on RusHydro Group’s Line of Trust (Order No. 689 of September 12, 2018) updating the procedure for processing and responding to the reports received through the Line of Trust.
  • Amendment of the Rules of RusHydro’s Line of Trust Operation to change the 24/7 hotline number (Order No. 1018 of December 27, 2018);
  • Amendment of the Code of Corporate Ethics in terms of the measures designed to prevent the substantial shareholders’ misconduct in connection with the Company’s transactions involving a conflict of interestTransactions involving a conflict of interest are the Company’s transactions with persons affiliated with (related to) substantial shareholders of RusHydro (other than the Russian Federation) aimed at receiving unjustified profit (enrichment) at the Company’s expense. , as well as mitigating the effects of such misconduct (the Board of Directors minutes No. 281 of December 27, 2018);
  • Update of the Regulations on the Procedure to Report Presents Received by RusHydro’s Employees (Order No. 60 of February 5, 2019);
  • Amendment of RusHydro’s Regulations on the Prevention and Management of Conflicts of Interest in terms of the procedure for considering notices of potential conflicts of interest of employees holding positions named in the list approved by Resolution of the Government of the Russian Federation No. 613 of July 22, 2013 and clarifed by the Executive Offce of the Government of the Russian Federation No. P 17 - 69370 of December 29, 2018. (Order No. 44 of January 29, 2019).
Providing for transparency and availability of information on the Company’s anti-corruption policy and ensuring employees ’ awareness of anti-corruption legislation
  • The following information is published on RusHydro’s website and intranet portal and updated on a timely basis:
    • the Company’s local internal documents on combating corruption and preventing wrongdoings and conflicts of interest;
    • action plans and reports on the implementation of the Comprehensive Program of Anti-Corruption Activities;
    • information, effective laws and regulations, and guidance on combating corruption.
    • RusHydro has put in place a permanent «Line of Trust» a communication channel available to RusHydro Group’s employees and third parties (including anonymous) to report issues in an effort to combat fraud and corruption, prevent wrongdoings and conflicts of interest, and improve RusHydro’s operations.
  • In 2018, the Company developed and placed in its offices and branches new roll up banners providing information about the Line of Trust, and released a video displayed regularly in the Company’s offices.
Providing for investigations into any reports of wrongdoings
  • In 2018, the Company considered 195 reports received through the Line of Trust, of which 67 (34%) were confirmed to be true and involve violations of rights and/or other wrongdoings. The Company took measures to eliminate all verified violations.
Cooperating with the state regulatory bodies and law enforcement authorities responsible for combating corruption
  • In 2018, the areas of the Company’s cooperation with government authorities (the Government of the Russian Federation, the Ministry of Energy of Russia, etc.) included:
    • disclosure of information upon an authorized request;
    • reporting on the Company’s anti-corruption practices;
    • filing queries for the clarification of anti-corruption law enforcement practices;
    • sending proposals on amending Article 13.3 of Federal Law No. 273-FZ On Combating Corruption of December 25, 2008 (draft).
Measures to prevent wrongdoings by the Company’s employees
  • In 2018, following the amendments of legislation and RusHydro’s internal local documents, the Company updated its corporate distance learning courses: Combating Fraud at RusHydro and Combating Procurement Fraud.
  • In December 2018, the employees of the Headquarters, branches and subsidiaries of RusHydro holding positions exposed to corruption risksThe list of the positions exposed to corruption risks was approved in accordance with the Company’s Anti-Corruption Policy. were tested to check their knowledge of Russian anti-corruption laws and the Company’s local internal documents on combating corruption.
  • In 2018, as part of the effort to identify and resolve conflicts of interest, the Company collected and checked 2017 income records of 387 employees (the top management of RusHydro and its subsidiaries). As a result, 40 officers failed to comply with the relevant requirements. In 2018, as part of the effort to identify and resolve conflicts of interest, the Company collected and checked 2017 income records of 387 employees (the top management of RusHydro and its subsidiaries). As a result, 40 officers failed to comply with the relevant requirements.
    In response to all 40 cases of non-compliance, RusHydro’s Central Ethics Committee, after reviewing the results of the declaration for 2017, issued recommendations on the elimination of the identified gaps and violations, prevention or resolution of actual and/or potential conflicts of interest and use of disciplinary action.
Enhancing internal control system
  • RusHydro develops, updates and implements internal control improvement plans on an annual basis. For more information on relevant initiatives, see Risk management section of this report.

Anti-corruption awareness program and training [205–2]

The Company promotes awareness and educates employees on anti-corruption practices. The Company’s anti-corruption measures include, among other things:

  • distance learning induction for new (newly hired) employees of the Company, featuring information on this Policy;
  • regular training on preventing and combating corruption in the Company;
  • individual consultations for the Company’s employees regarding the application of anti-corruption standards and procedures.

RusHydro conducts annual assessment of employees in the positions with high exposure to corruption risk in order to test their knowledge of the anti-corruption laws.

Employee training in the existing anti-corruption policies in 2018
Region Top management Middle management Junior management White-collar employees
Number of people % of employees Number of people % of employees Number of people % of employees Number of people % of employees
Moscow 14 11.67 30 25.00 63 52.50 13 10.83
Republic of Dagestan 3 27.27 3 27.27 1 9.09 4 36.36
Kabardino-Balkarian Republic 1 14.29 6 85.71
Karachay-Cherkess Republic 1 7.14 9 64.29 4 28.57
Republic of North Ossetia – Alania 1 11.11 2 22.22 5 55.56 1 11.11
Amur Region 8 36.36 10 45.45 4 18.18
Volgograd Region 3 37.50 4 50.00 1 12.50
Perm Territory 6 28.57 10 47.62 1 4.76 4 19.05
Samara Region 4 30.77 4 30.77 5 38.46
Moscow Region 5 55.56 3 33.33 1 11.11
Yaroslavl Region 5 55.56 2 22.22 2 22.22
Stavropol Territory 5 62.50 2 25.00 1 12.50
Nizhny Novgorod Region 5 50.00 4 40.00 1 10.00
Novosibirsk Region 3 21.43 7 50.00 4 28.57
Saratov Region 3 37.50 3 37.50 2 25.00
Republic of Khakassia 4 36.36 6 54.55 1 9.09
Chuvash Republic 4 36.36 5 45.45 2 18.18
Total 75 24.6 110 36.1 70 23 50 16.4