Company Statement
The Company represents that, pursuant to the United Nations Convention Against Corruption dated October 31, 2003, ratified in the Russian Federation in 2006 (most of the Convention provisions ratified) and the Russian Federal Anti-Corruption Law, adopted in its development, and in view of the ratification of the European Council Convention "On Criminal Liability for Corruption", Rosneft, being an international public Company, has adopted regulatory documents aimed at increasing transparency and counteracting corruption, including "Policy on the Prevention of Involvement in Corrupt Practices". Based on these corporate regulatory documents, a list of positions has been approved, where the employees holding such positions are obliged to provide information on their income, property titles and property liabilities to the Company, both for themselves and their spouses and underage children. The list includes the positions of the Chairman of the Board, Vice-Presidents, Company Chief Accountant, heads of business units and their deputies, heads of departments and their deputies, directors of subsidiaries and their deputies.
Rosneft has also adopted a number of other regulations aimed at eliminating legal and reputational risks, e.g. the Company has implemented the “Rosneft Code of Business and Corporate Ethics”, the provisions of which are mandatory for all managers and employees, and an electronic notification system for reporting the Code violations.
The Board of Directors regularly assesses the corruption risks inherent to the industries and jurisdictions where the Company business is performed. The Board also reviews the disclosed occurrences of the conflict of interest, for which appropriate response actions are taken, up to and including termination of employment. Since the introduction of the above procedures, a number of employees who had committed gross violations of corporate standards have been dismissed. Some case files have been submitted to the law enforcement agencies of the Russian Federation.
Rosneft has performed a scope of actions to apply transparent mechanisms and implement efficient procurement procedures. The Company also regularly interacts and exchanges information with government supervisory bodies, in particular, with the Russian Ministry of Finance, Federal Financial Monitoring Agency, Russian Audit Chamber, and the Central Bank of the Russian Federation.
Definition of corruption
Pursuant Article 1 of Federal Law No. 273-FZ of 25.12.2008 "On Counteracting Corruption", the following actions are recognized as corruption:
a) abuse of power, giving or receiving bribes, abuse of authority, commercial bribery or other unlawful use of their official position by an individual, contrary to the legitimate interests of the society and the state, in order to obtain benefits in the form of money, valuables, other property or services of a property nature, other property rights, for themselves or for third parties, or unlawful provision of such benefits to such a person by other individuals;
b) committing the acts specified in subparagraph "a" above, on behalf of or in the interests of a legal entity.
Rosneft is a public company with securities traded in Russian and foreign trading facilities, including PJSC Moscow Stock Exchange and the London Stock Exchange; therefore the Company's activities and actions of its employees in any country worldwide are to comply, inter alia, with the requirements of the Russian anti-corruption legislation, the UK Bribery Act 2010, the FCPA (Foreign Corrupt Practices Act 1977) and provisions of other laws and regulations of foreign countries where the Company operates or intends to run its business.
The Company Policy "On counteracting involvement in corrupt activities" provides the following definition:
Corrupt actions imply offering, giving, promising, extorting or receiving bribes, mediating bribery, making payments to simplify administrative, bureaucratic and other formalities in any form, including cash, other valuables, services or provision / receipt of unjustified tangible or intangible benefits from any individuals / organizations or to any individuals / organizations, including government representatives, public groups, private companies and politicians.