Adherence to Ethical Principles
Anti‑Corruption
Understanding its major obligation to the public, regulators and authorities, the Rosseti Group enforces uniformly strict standards in the field of anti‑corruption laws. These are systematic efforts enshrined in the Russian Federation’s Strategy for the Development of the Power Grid Sector, which mandates that Rosseti oversee the anti‑corruption efforts of all grid operators.
Companies in the Rosseti Group have joined the RUIE Anti‑Corruption Charter of the Russian Business and are creating and putting into practice an array of organisational, elucidating and other measures to guarantee that employees abide by the rules, regulations and guidelines put in place to prevent corruption and standardise anti‑corruption practices.
The Rosseti Group put in place a unified Anti‑Corruption PolicyApproved by the resolution of the Board of Directors of the Company dated 7 June 2023 (Minutes No. 620 dated 7 June 2023)., Code of Corporate Ethics and Conduct for EmployeesApproved by the resolution of the Company’s Board of Directors, Minutes No. 372 dated 29 June 2017., Regulations on Prevention and Settlement of Conflicts of Interest, Procedure for Receiving and Processing Complaints of Applicants on Possible Facts of Corruption Received through the Hotline, Anti‑Corruption Standard and other local regulations on corruption prevention.
Power grid companies state unequivocally that they do not tolerate corruption of any kind. This means that managers, staff members and other individuals working for or on behalf of the companies — directly or indirectly, in person or through an intermediary — are not allowed to participate in corrupt activities.
Anti‑corruption initiatives at the Rosseti Group are designed to lower the likelihood that the Company would suffer material or reputational harm as a result of corruption offences.
The provisions of the Anti‑Corruption Policy and Code of Ethics apply to PJSC Rosseti’s employees, business partners and counterparties, and other stakeholders by virtue of anti‑corruption obligations and agreements.
— Russia cannot thrive economically unless the business and the state work together to address challenges related to preventing corruption. Rosseti, as an organisation that is listed highly among those deemed strategically important to the economy, upholds the highest standards of business ethics and best practices.
A revised version of the Anti‑Corruption Policy of PJSC Rosseti and its subsidiaries, which was approved by the Board of Directors in 2023, outlines a uniform approach for complying the Anti‑Corruption Law’s provisionsArt. 13.3 of Federal Law No. 273-FZ dated 25 December 2008.. There is a concerted effort to stop and prevent corruption. PJSC Rosseti is to coordinate the activities of all grid operators in this area.
Having joined the RUIE Anti‑Corruption Charter of the Russian Business, the Company voluntarily develops and puts into practice the organisational, elucidating and other measures to guarantee that employees abide by the rules, regulations and guidelines put in place to prevent corruption and standardise anti‑corruption practices. The business community really appreciates the outcomes of our efforts. According to the President of the Russian Federation’s directives regarding the National Anti‑Corruption Plan, the Rosseti Group’s anti‑corruption measures system received the highest grade of ААА+ and a top ranking in the fourth national Anti‑Corruption Rating of Russian Business, which was conducted by the Russian Union of Industrialists and Entrepreneurs (RUIE) in September 2023. Independent experts evaluated 30 compliance criteria for the Rating, which involved over 70 companies.
Gaining the national rating is crucial to enhancing the Rosseti Group’s standing in the eyes of the public, media, investors, partners, counterparties, government authorities at all levels, and members of the management team in the regions where the Group operates.
However, the efficacy of anti‑corruption efforts hinges not only on the laws and policies put in place, but also on how honest and morally upright every employee is in their everyday dealings. Since the state is the Rosseti Group’s controlling shareholder, we must work together to eradicate any chance of corruption among our employees.
Management of Conflict of Interest
To mitigate the impact of employees’ personal and private interests on their job duties, the Rosseti Group implements strategies to detect, avoid and settle conflicts of interest.
Pursuant to clause 2.4.5 of the Anti‑Corruption Policy, PJSC Rosseti and its subsidiaries conduct an annual declaration of conflicts of interest.
Since 2017, the Rosseti Group has a separate subsystem in place for electronic declaration of conflicts of interest integrated with the unified information and analytical system for verifying legal entities and individuals of the Rosseti Group (UIAS Security) and the internal Automated System for Analysing and Collecting Information on Beneficiaries (AS ACIB).
In 2023, annual declarations of conflicts of interest covered 50,272 employees of PJSC Rosseti and 20 subsidiaries. As a result, 17 conflicts of interest and 46 pre‑conflict situations were identified and resolved during 2023.
In 2023, the Central Commission of PJSC Rosseti for Corporate Ethics Compliance and Conflict of Interest Resolution and the commissions for Corporate Ethics Compliance and Conflict of Interest Resolution of the Rosseti Group held more than 190 meetings with the participation of employees of the security unit. As a result, more than 170 pre‑conflict situations were identified and resolved.
To identify any signs of affiliation, conflicts of interest, pre‑conflict situations and completeness of the certificates, the 2022 statements on income, property, and property obligations of managers of PJSC Rosseti and its subsidiaries and their close relatives were screened, covering 396 declarants, including 55 managers of PJSC Rosseti and 341 managers of subsidiaries of PJSC Rosseti, and 1,551 close relatives of declarants.
Based on the results of the verification, no signs of affiliation, conflicts of interest, pre‑conflict situations or other abuses were identified.
In the reporting period, 591 candidates for employment with the Company were screened (more than 29,510 candidates were screened across the Group as a whole), with four negative opinions given (non‑compliance with qualification requirements, availability of compromising information). In general, more than 1,170 negative opinions were given across the Rosseti Group.
Anti‑Corruption Control of Procurement Activities
The Rosseti Group has the AS ACIB in place, allowing it to confirm the reliability of data submitted by counterparties, and detect any sign of affiliation, conflicts of interest, pre‑conflict situations and other abusive practices. With the disclosure of counterparties’ ownership chain in 2023, the Rosseti Group was able to identify over 48,500 beneficiaries.
In 2023, the Rosseti Group audited more than 78,160 participants in the Rosseti Group’s procurement procedures. Over 3,500 violations (such as conflict of interest, affiliation, price collusion, document falsification, and employee lobbying of participant interests) were found during screening activities. Appropriate action was taken for these violations, which included rejecting over 2,900 participants from procurement procedures.
According to the findings of the initial (maximum) price justification review, the Rosseti Group enjoyed resulting savings during procurement procedures initiated by subsidiaries’ safety units totalled over RUB 1.69 billion.
Every anti‑corruption compliance mechanism was put into place in keeping with the guidelines provided by PJSC Rosseti’s 2023 Anti‑Corruption Plan and the National 2021–2024 Anti‑Corruption PlanApproved by Decree of the President of the Russian Federation No. 478 dated 16 August 2021.. No criticism was received from regulatory agencies, and all directions were followed.
The Company makes sure to publicise its anti‑corruption initiatives and actively collaborates with government authorities.
In 2023, the Rosseti took part in the Anti‑Corruption Rating of Russian Business conducted as part of the National Anti‑Corruption Plan approved by the Decree of the President of the Russian Federation.
According to the Rating Committee’s decision, the Rosseti received the highest grade of ААА+ for the fourth year in a row, as well as retained its place among Russian top companies, which, as noted by the Russian Union of Industrialists and Entrepreneurs, the organiser of Rating 2023, “results from the strong focus of the Company’s management on improving the corruption prevention and counteraction system”.
