Providing for transparency and availability of information [102–17]
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 works in close cooperation with the law enforcement authorities and supervisory bodies and provides assistance to them in case of audits and inspections, requests of information on the Company’s anti-corruption compliance (including with respect to storage and transfer to the authorities of the information and documents on corruption offences), investigations of corruption cases, and inspections seeking to check how the Company prevents and combats corruption.
In 2018, the Company completed the integration of RusHydro Group’s hotlines into the single Line of Trust and updated the Regulation on the Procedure for Accepting, Processing and Responding to the Reports Received through the Line of Trust, which sets the list and responsibilities of the officers and divisions in charge of receiving and considering reports, and defines the procedure for responding to them.
The information on the ways to file a report is available on notice boards and information screens in the offices of RusHydro Group companies.
The results of the Line of Trust’s operation are disclosed on the Company’s intranet portal and in the corporate newsletter.
Line of Trust
In 2018, the Company reviewed 195 reports received through the Line of Trust. The reports that did not meet the criteria set by the Rules of RusHydro’s Line of Trust Operation (email spam, advertisements, mass mailing, etc.) were not accepted. The number of reports increased by 17% year-on-year.
The increase was mainly driven by the integration of RusHydro’s Line of Trust, its promotion, as well as the Group’s organizational changes made to improve performance of electricity retailers that included deployment of new software, unified payment documents, etc.
Information contained in 67 (34%) was confirmed to be true and involve violations of rights and/or other wrongdoings. The Company took measures to eliminate the verified violations:
- based on three reports, disciplinary action (reprimand, censure) was taken against five employees (managers) of RusHydro Group, who committed violations;
- two reports resulted in the managers being stripped of their bonuses;
- Two employees (one of them being a manager) faced termination of their employment contracts by mutual consent;
- organizational measures, including:
- preventive discussions;
- necessary employee training;
- amendments made to procurement documents, cancellation/postponement of procurement procedures;
- payment adjustments;
- other measures aimed at eliminating identified gaps and violations.