Document Information

Purpose of the document

By this Policy, the Company, its management and the Board of Directors set the following objectives:

  • to take measures aimed at improving the corporate culture of the Company, introducing and developing best corporate governance practices in the Company, as well as standards of responsible business conduct;
  • to express adherence of the Company to the principles of legality, transparency and social responsibility in order to maintain its high business reputation with the state, shareholders, counterparties, partners, competitors and the society as a whole;
  • to specify the principles aimed at prevention of any manifestations of corruption, both on behalf of and in relation to the Company and (or) with its employees, as well as the compliance with, regardless of the circumstances, the requirements of the applicable anti-corruption legislation during Company’s business in any country of the world;
  • to minimize risks of involving the Company, the members of the Board of Directors, employees and representatives of the Company in corruption;
  • to ensure the uniform understanding of the Company's policy on the corruption aversion in all its forms and manifestations by the shareholders, the investment community, counterparties, employees, their members of the management bodies, workers and other persons of the Company and Group of Companies;
  • to summarize and explain the basic requirements of the anti-corruption legislation of the Russian Federation that can be applied to the Company and employees.
Document overview
  • the anti-corruption policy is a document of corporate value;
  • the policy establishes basic principles and requirements to compliance with the provisions of anti-corruption legislation applicable to NVision Group JSC (hereinafter referred to as NVision Group JSC, the Company), by NVision Group JSC, all of its subsidiaries and affiliates, members of their management bodies and employees, as well as all third parties, acting on behalf of and/or for the benefit of NVision Group JSC and its subsidiaries and affiliates;
  • the policy governs the activities of all employees of the Company;
  • principles and requirements of this Policy apply to counterparties and representatives of the Company, all subsidiaries and affiliates of NVision Group JSC, their members of management bodies and employees, as well as to other persons, in cases where corresponding duties are recorded in contracts therewith, in their internal documents, or directly follow from the law;
  • the President of NVision Group JSC shall be responsible for organization of all activities aimed at implementing the principles and requirements of this Policy, including the appointment of persons responsible for development of anti-corruption procedures, their implementation and control.

Definitions of terms

Term Abbreviation Term definition (abbreviation expansion)
Introduced definitions:
Employees (for the purposes hereof) Individuals in employment relations with the Company, or who executed a civil agreement with the Company.
Representatives Mediators, consultants and all categories of other third parties acting for the benefit of and (or) on behalf of the Company.
Applicable anti-corruption legislation The Russian anti-corruption legislation, FCPA, UK Bribery Act and similar legislation of other countries where the Company conducts its business.
Russian anti-corruption legislation Federal Law dated December 25, 2008 No. 273-FZ “On Counteraction to Corruption”, Criminal Code of the Russian Federation, Civil Code of the Russian Federation, the Code of the Russian Federation on administrative offences, and also other Federal Laws and subordinate legislation of the Russian Federation containing norms aimed at combating corruption with all subsequent amendments and (or) additions thereto.
Foreign Corrupt practices Act FCpA The Foreign Corrupt Practices Act 1977 (FCPA) as passed by the US Congress in 1977.
UK Bribery Act The UK Bribery Act 2010 as passed by the Parliament of Great Britain in 2010.
State authorities, institutions and enterprises State authorities of the Russian Federation and foreign states, their subjects and local self-government (including government ministries, services and agencies), offices of state and their structural subdivisions, political parties and all (directly or indirectly) state-controlled legal entities.
Anti-Corruption Compliance (Anti-Corruption Compliance System) A system of actions and procedures developed by the management of the Company for the purposes of ensuring compliance with the requirements of the anti-corruption laws applicable to the Company.
Business Sponsorship Partnership (sometimes of barter type), making it possible for NVision Group JSC to achieve strong and positive association with the object of sponsorship, i.e. strengthening loyalty to the brand. Business sponsorship provides for mandatory activation of sponsorship rights by BTL-tools. It is not charitable sponsorship, is aimed at expansion of the customer base and increasing sales.
BTL (below the line)

A complex of marketing communications, which differs from direct advertising ATL (above-the-Line) by method of impacting the target audience.

A complex of marketing communications, which within promotion of NVision Group JSC includes events, organization of exhibitions, conferences, workshops, digital and special projects, non-standard programs and business sponsorship. BTL makes it possible to deliver an advertising message or solicitation to purchase directly to the end customer.

BTL-promos shall not contain programs stimulating consumer activities, contents of which violate the requirements of the applicable anti-corruption legislation.

Applicable definitions:

Company

NVision Group JSC (Joint Stock Company NVision Group), including all units, branches and representative offices.

NVision Group of Companies includes NVision Group JSC, all subsidiaries and affiliates of NVision Group JSC, and also all companies under direct or indirect control by NVision Group JSC.

Governmental official

GO

Any Russian or foreign, appointed or elected person holding any position in the legislative, executive, administrative or judicial body or international organization; any person performing any public role for the state, including roles for a governmental body, institution or enterprise; leading politicians, officials of political parties, including candidates for political posts, ambassadors, influential functionaries in nationalized industries or natural monopolies; managers and employees of state bodies, institutions and enterprises, including doctors, military personnel, municipal employees, etc.; persons who are known to be related to a state official by kin or in terms of friendly or business relationships.

Compliance (compliance)

Carrying out the company’s actions in accordance with the applicable legislation, requirements of the regulators and stock exchanges, industry standards, best practices and moral and ethical norms.

POLICY OBJECTIVES

This Policy solves the following practical tasks for achieving the Policy Objectives:

  • to notify the members of the Board of Directors, employees and representatives of the Company about their obligation to know and comply unconditionally with the key principles of compliance with the applicable anti-corruption legislation specified herein, as well as the actions and procedures used by the Company to prevent corruption;
  • to establish obligation of the Management and the Board of Directors of the Company to ensure and oversee the development and implementation of effective system of compliance with applicable anti-corruption legislation;
  • to prevent participation of the Company, the members of the Board of Directors, employees and representatives of the Company in corruption;
  • to minimize risk of the Company, members of the Board of Directors and employees of the Company to be held liable as per criminal, administrative or civil liability;
  • to establish common understanding of the Company’s policy regarding prevention of corruption in any forms and manifestations among the members of the Board of Directors, employees, representatives, subsidiaries and affiliates of the Company;
  • to strengthen measures to ensure the accuracy and transparency of the Company’s financial statements, as well as lawful and efficient use of its assets.
APPLICABLE ANTI-CORRUPTION LAW

This Policy has been developed in accordance with the requirements of the anti-corruption legislation of the Russian Federation, Foreign Corrupt Practices Act 1977 as passed by the US Congress in 1977, UK Bribery Act 2010 as passed by the UK Parliament in 2010, recommendations of regulatory authorities and similar legislation of states, where the Company operates, as well as the Charter, Code of Business Conduct and Ethics and other internal documents of the Company.

In Russia and other countries of the world, “corruption” will usually be considered as giving or receiving bribes, mediating in giving or receiving bribes, abuse of official position or authority, commercial bribery, payments to simplify formalities, illegal use of official’s position to gain benefit in the form of money, valuables, other property, services, any rights for oneself or for other persons, or unlawful provision of benefit or rights to this person by other persons.

In view of the above, employees of the Company shall not, directly or indirectly, personally or through third parties, be engaged in corrupt activities, offer, give, authorize, promise, ask and receive bribes or make payments to induce improper performance of official duties or simplify administrative, bureaucratic and other formalities, for improper fulfillment of duties, in any form, including in the form of cash, valuables, services or other benefits, to any persons and from any persons or organizations, including commercial organizations, governments and authorities, governmental officials, private companies and their representatives.

The Company and its employees must comply with anti-corruption legislation of the Russian Federation, as well as the principles and requirements of the Policy, in all countries of the world.

KEY PRINCIPLES

The Company adheres to the principles of compliance with anticorruption legislation and ethical business conduct in all types of business relations and regardless of the country in which the Company pursues its business. Principles and requirements hereof shall be binding for all legal entities within NVision Group of Companies, including their employees, members of the management bodies and representatives.

The Company fixed the principle of non-acceptance of corruption in any forms and occurrences both in everyday activities and when implementing strategic projects./p>

Therefore, all employees and members of management bodies of the Company, as well as any third party acting on behalf of and/or for the benefit of the Company, shall be prohibited:

  • to offer, promise, authorize or make payments in the form of cash or any other assets, including, but not limited to, business gifts, reimbursement of expenses, discounts, entertainment, etc., as well as any financial or other benefit or advantage to any GO, representative of a commercial organization or any other person in order to influence his or her actions (to ensure inaction) and to induce to perform official duties in an inappropriate manner and/or to obtain an inappropriate commercial advantage;
  • to demand or consent to the receipt, or actually receive, any payments in the form of cash or any other valuables, as well as any financial or other gain or advantage, where the receipt of such payments, gain or advantage in and of itself represents the improper performance of the receiver’s official duties or their responsibilities otherwise envisioned by applicable law or is a compensation for improper performance of such duties;
  • to mediate in bribery or commercial bribery, i.e. directly transfer bribes as instructed by a bribe-taker or bribe-recipient, or otherwise help the bribe-taker and/or bribe recipient in achieving or executing agreement between them on receiving and giving the bribe or commercial bribery.
Mission of the management

The management and members of the Board of Directors of the Company shall set the standard of ethical behavior by their own behavior, using a personal example, establish employees’ uncompromising attitude to any forms and manifestations of corruption, which shall become an integral part of corporate culture and daily business practice of Company’s employees.

Management and members of the Board of Directors of the Company shall be aware of the contents of the anti-corruption compliance system, shall allocate the necessary resources for its implementation and provide general monitoring over its implementation, discipline of performance and operational efficiency.

Reputation of the management

The Company takes reasonable actions to prevent hiring individuals who are known to take or to have taken part in illegal activity to Company executive positions or to the management bodies.

Consistent application of the policy

The Company shall consistently provide for compliance with the applicable anti-corruption legislation, namely promote principles of ethical business conduct, and in particular motivates employees and representatives of the Company to adhere to the principles of compliance with this Policy, as well as invariably apply sanctions in all cases of violating the provisions hereof.

Periodic risk assessment and minimization

The Company regularly (at least once in two years) conducts measures for discovery, assessment and reassessment of corruption risks paying special attention to risks specific for its activities, regions of operations as well as potentially vulnerable business-processes.

Following assessment and reassessment results, the Company develops and implements anti-corruption procedures reasonably and proportionally meeting the level and nature of discovered risks.

Notification and training

The Company openly announces opposition to corruption and requests that its employees, members of the Board of Directors, representatives, subsidiaries and affiliates, members of their management bodies and employees unconditionally comply with the principles and requirements hereof.

The Company continuously monitors all changes in regulatory requirements and law enforcement practice of the applicable anti-corruption legislation and timely notifies all stakeholders about relevant changes and trends.

The Company implements and maintains the program of training for managers (including members of the Board of Directors), employees and representatives in principles and standards of compliance with applicable anti-corruption legislation by means of a training system specially developed for the purposes of this Policy.

Trainings shall be held when employed in the Company; annually in electronic form; on a regular basis in full time form, but at least once in two years; and also whenever necessary, including material changes to the Applicable Anti-Corruption Legislation or anti-corruption procedures of the Company.

The Company by means of informing and training contributes to the increase of the level of corporate culture, awareness of anti-corruption and business ethics issues.

Monitoring and control

The Company exercises monitoring of efficiency of implemented procedures for corruption prevention, monitors compliance and, if required, improves them.

Responsible official

In order to ensure compliance with applicable anti-corruption legislation, the Company has appointed an official, directly under the President of the Company, responsible for the implementation and improvement of the compliance system (Compliance Manager).

The Compliance Manager has the necessary experience and competence and is also provided with independence, powers and resources sufficient for the effective implementation and improvement of the corporate system of compliance with the applicable anti-corruption legislation.

The Compliance Manager shall monitor compliance with the requirements of this Policy and the applicable anti-corruption legislation, as well as operational management of the compliance system and its continuous improvement.

Reporting to the President and the Board of Directors

The Compliance Manager shall regularly and whenever required report to the Board of Directors and the President of the Company about the implementation process and/or improvement of the anti-corruption compliance system, detected over the reporting period violations of the compliance procedures, conducted internal investigations, weaknesses of the internal compliance controls and measures taken in this regard, also about general status of functioning and efficiency of the system.

The Compliance Manager shall be a member of collective bodies of the Company and shall be directly involved into making decisions of both strategic and operational nature.

CONTRACTUAL POLICY
Prohibition of non-contractual agreements

КThe Company prohibits on its behalf or for its benefits to enter into any non-contractual agreements with any categories of counterparties, namely, any written or oral agreements that are not included in the main text of the contract with the counterparty or its annexes, or in any other form, and, accordingly, those that have not been through the standard approval procedures adopted in the Company.

Any contract entered into with a third party in its written form, including all annexes thereto, being an integral part thereof, shall contain the fullness of the terms and conditions on which such a contract is concluded.

Anti-corruption clause

In order to comply with the Applicable Anti-Corruption Legislation and to minimize risk of liability as a result of Company’s involvement into corruption, according to the general rule, the Company shall initiate inclusion of an anti-corruption clause into any executed expense contracts/agreements.

COUNTERPARTIES DUE DILIGENCE

The Company shall take reasonable efforts to minimize risk of establishment of business, labor and other relations with individuals or legal entities, who may be involved into corruption, and, therefore, expose the Company to the risk of involvement into such activities.

For the purposes of minimization of the risk of Company’s involvement in corrupt practices, the Company developed and implemented due diligence procedures compliant with the requirements of the applicable legislation both in respect of contract parties — legal entities (including members of joint ventures, companies or associations) and in respect of individuals with whom the Company plans to enter into a labor contract or a civil law contract.

This procedure is also applied if the Company acquires a stake in some legal entities. The due diligence procedure related to scheduled acquisition shall include both proper investigation of the object of acquisition, its owners and management, and inspection of the objective and procedure for closure of such transaction in accordance with the requirements of this Policy and Applicable Anti-Corruption Legislation.

SUBSIDIARIES, JOINT VENTURES AND COUNTERPARTIES

The Company pays special attention to assessment of counterparties’ tolerance of corruption, including checking for availability of their own systems for compliance with the anti-corruption legislation, their readiness to adhere to the requirements hereof and to include anti-corruption clauses into contracts.

In relations with its suppliers, representatives and other counterparties, the Company takes active actions aimed at prevention of any manifestations of corruption, both on behalf of and in respect to the Company. Herewith, the Company requires that its suppliers, representatives and other contracting parties adhere to the principles of compliance with the Applicable Anti-Corruption Legislation, as well as mutually support the culture that denies any unethical corporate conduct, both when participating in procurement procedures of the Company and subsequent conducting business with the Company.

The Company shall initiate in controlled subsidiaries the introduction of its own anti-corruption policies, similar to this Policy, and shall also make reasonable efforts to ensure that the fundamental principles and requirements of this Policy are observed in joint ventures, companies and associations, where the Company participates.

GIFTS AND REPRESENTATION EXPENSES

In accordance with applicable anti-corruption legislation, gifts and representation expenses, including business entertainment expenses that employees may make on behalf of the Company for other individuals or entities, or that employees in connection with their work in the Company, may receive from other individuals and organizations, under certain circumstances may be interpreted as illegal. Therefore, any gifts and entertainment expenses shall correspond to a set of the following criteria:

  1. be directly connected with the legitimate objectives of the Company’s activities, for example, with the presentation or completion of business projects, promotion of goods or services, successful execution of contracts, or with public holidays, such as Christmas and New Year, International Women’s Day, memorable dates, anniversaries, etc.;
  2. be reasonably justified, commensurable and not include or consist of luxury goods;
  3. not compromise the ability of a recipient to make unbiased and fair decisions in connection with their service and other authorities (duties), namely, without limitation, grant preferential attitude or abilities in exchange of information, which would not be granted otherwise;
  4. shall not represent a hidden reward for a service, action, omission, connivance, patronage, granting of rights, making a specific decision on a transaction, agreement, license, authorization, etc. or an attempt to influence the recipient with another illegal or unethical purpose;
  5. shall not create a reputation risk for the Company in case of disclosure of information on such gifts or entertainment expenses;
  6. shall not be prohibited by legislation or by other procedures and policies applicable to the recipient;
  7. shall not impose any moral obligations on the recipient;
  8. shall not contradict with the principles and the requirements of this Policy, the Code of Business Conduct and Ethics, other internal documents of the Company and norms of the Applicable Anti-Corruption Legislation;
  9. go through the necessary approval procedures in the Company, be authorized by the senior manager and documented thoroughly.

The specified criteria shall also cover all expenses to organize on behalf of and/or at the expense of the Company the actions aimed at stimulating consumer activities, engaging, retaining or developing the base of contractors, and also actions related to Company’s activity in the field of public relations, media, investment and professional community.

Gifts may not be made on behalf of the Company, members of the Board of Directors, employees and representatives to any third parties in the form of funds, cash or bank, and also their equivalents in any currency.

The rules and restrictions regarding donating and accepting gifts, as well as organizing entertainment events and participating in them, established in NVision Group JSC, are set out in the Regulations “On Gifts and Entertainment Events” (Annex 1).

Charity, SPONSORSHIP AND CORPORATE SOCIAL RESPONSIBILITY

The company is committed to participate in the implementation of social responsibility projects, to support the initiatives of governments and charitable organizations aimed at the welfare of the Company and its development, as well as makes a contribution to the creation of equal opportunities in countries where the Company operates.

To achieve these objectives, as well as in order to comply with applicable anti-corruption legislation, the Company has developed and implemented regulations and procedures governing the Company’s participation in charitable activities; all financial transactions related to sponsorship or charity activities are reflected in detail and reliably in the accounting records; implemented projects are subject to prior approval; procedures for monitoring charitable contributions allow you to make sure that contributions made are not a hidden form of bribe or commercial bribery.

In accordance with this Policy and the implemented procedures, the Company shall not finance and shall not participate in any other way in charitable activities in order to obtain any undue advantages or preferences in connection with economic activities.

NVision Group JSC does not participate in sponsorship activities, except for business sponsorship events.

FINANCING OF POLITICAL ACTIVITIES

In accordance with this Policy, the Company shall not finance and in no other way support or encourage political parties or their members, including candidates for political posts, their election campaigns or political events, as well as any political organizations or movements.

PAYMENTS THROUGH INTERMEDIARIES OR IN FAVOR OF THIRD PARTIES

The Company, members of its Board of Directors and employees shall not involve or use representatives of the Company, joint ventures or other third parties to perform any actions that contradict the key principles and requirements of this Policy or the Applicable Anti-Corruption Legislation.

The Company, members of its Board of Directors and employees shall not make payments for the benefit of the Company’s representatives, joint ventures or other third parties, if it is known with a high degree of confidence (or it should be known), that the entire payment or its part will be made for corruption purposes.

The Company shall provide for completion of due diligence procedures in respect to representatives, joint ventures and other third parties to prevent and/or identify the violations above in order to minimize risks of Company’s involvement into corruption.

ACCOUNTING PROCEDURES

All financial operations, postings and records shall be reflected accurately, correctly and with the sufficient level of detail in the Company's accounting records, documented and available for audit.

The Company developed and implemented the procedures of internal financial control aimed at the following:

  1. all financial transactions are performed in accordance with the general or special sanction of the management;
  2. accounting entries are made with such precision and detail that will make it possible to prepare statements complying with the applicable standards of accounting (financial) statements;
  3. access to disposal of assets is only provided in accordance with the general or special sanction of the management;
  4. accounting entries about cost and scope of assets are regularly compared to actual cost and scope, and whenever required, relevant actions are taken.

The Company shall appoint employees responsible for the preparation and submission of complete and reliable accounting statements within the time frames provided for by the applicable law.

Failure to comply with or an attempt of failure to comply with the procedures of internal financial control, misstatement or falsification of accounting statements of the Company shall be strictly prohibited and are a violation of the law.

AUDIT AND CONTROL

The Company regularly conducts internal and external audits of financial and economic activities, as well as continuously monitors the completeness and accuracy of all business transactions in accounting and compliance with applicable laws and internal regulatory documents of the Company, including the principles and requirements established this Policy.

Within the framework of internal control procedures, the Company shall conduct inspections of the discipline of compliance with the established procedure for implementation of business processes, including spot inspections of the lawfulness of operations with Company’s assets made, their economic feasibility, the appropriateness of expenses, including confirmation by primary accounting documents and compliance with the requirements of this Policy.

REPORTING VIOLATIONS

Each employee of the Company, regardless of his or her position, a member of the Board of Directors or a representative of the Company that become aware of the facts (or their signs pointing at them) of a violation or inducement to violate the provisions of this Policy and/or Applicable Anti-Corruption Legislation by employees, members of the Board of Directors or Company Representatives, as well as third parties, shall report this in any of the following ways:

  • to Hotline of NVision Group of Companies within Unified Hotline of MTS Group of Companies using one of the following channels for information transfer:

    - е-mail: hotline@nvg.ru;

    - Hotline section of the corporate portal of NVision Group JSC.

  • sending a letter in free form through the corporate e-mail to the Compliance Manager personally or to the mailbox compliance@nvg.ru;
  • a message to the direct supervisor or, if the message concerns the actions of the direct supervisor, - to a top manager. the manager who received such information shall ensure the transmission of such data to the Compliance Manager.

The Company shall, within its powers, provide protection to the employees, who in good faith reported a violation or a suspected violation of the provisions of this Policy and/or Applicable Anti-Corruption Legislation, persecution or any form of discrimination on the part of the person against whom the message was made.

Besides, the Company guarantees that no employee will be subject to sanctions (including fired, demoted, deprived of bonuses etc.) from the Company, if the employee in good faith reported alleged corruption cases or if the employee refused to give or take a bribe, commit commercial bribery or mediate in bribery, including if, as a result of such a refusal, the Company lost profit or did not gain commercial or competitive advantages.

The Company guarantees to waive the application of sanctions shall not apply to guilty employees, as well as to cases when the internal investigation proved that the message was intentionally false, false testimony or slander.

RESPONSIBILITY

As the Company may be subject to sanctions for the participation of the members of its Board of Directors, employees, representatives, subsidiaries and affiliates and other persons related thereto in corrupt activities, each reasonable suspicion or established case of corruption will be used to initiate an internal investigation in accordance with internal regulatory documents of the Company, establishing the procedure for initiating and conducting such an investigation within the framework permitted by applicable laws.

Persons guilty of violating requirements hereof and applicable anti-corruption legislation, may be held liable as per disciplinary, administrative, civil or criminal liability at the initiative of the Company, law enforcement agencies or other persons in accordance with the procedure and under the grounds provided for by the Charter of the Company, internal regulations, labor and civil agreements, and also under certain circumstances and whenever there are grounds, in accordance with the Applicable Anti-Corruption Legislation and other similar foreign regulations.

POLICY EXECUTION

The owner of this Policy and the person responsible for development, introduction, improvement and monitoring of the anti-corruption compliance system of the Company shall be the Compliance Manager.

The management of the Company shall be liable for scope and efficiency of the corporate compliance system as a whole, and for provision of introduction and performance of controls and procedures of the anti-corruption compliance system in the areas of their functional competence.

The management, members of the Board of Directors and employees of the Company, regardless of position held, shall be personally responsible for compliance with the principles and requirements of this Policy and applicable anti-corruption legislation, as well as for the actions (inaction) of their subordinate individuals that violate these principles and requirements.

INFORMATION SOURCES

If any employee has questions regarding the content of this Policy, including questions of interpretation of any of its provisions, as well as doubts about the legality or ethics of their actions, the employee may ask for explanations from the Compliance Manager.

If any employee has questions related to the content of this policy, interpretation of any of its provisions, implementation of the principles and compliance procedures set forth in this Policy, including questions about the applicability of such principles and procedures in the various situations or business processes of the Company, as well as doubts about the legality or ethics of their actions, the employee may seek advice from the Compliance Manager, including sending his or her message to address of compliance compliance@nvg.ru.

Additional data on the functioning of the Company’s anti-corruption compliance system is posted on the Company‘s Unified Information Portal in the section: For employees/Useful information/Compliance.

Reference documents

External documents

Item No. Document name
1 Federal Law dated December 25, 2008 No. 273-FZ “On Counteraction to Corruption”
2 “Criminal Code of the Russian Federation” dated June 13, 1996 No. 63-FZ
3 “Code of the Russian Federation on Administrative Violations” dated December 30, 2001 No. 195-FZ
4 The Foreign Corrupt Practices Act 1977 (FCPA) as passed by the US Congress in 1977
5 The UK Bribery Act 2010 as passed by the Parliament of Great Britain in 2010
6 US Federal Sentencing Guidelines Manual, §8B2.1., 2010
7 The Bribery Act 2010 Guidance, 2011
8 A Resource Guide to the U.S. Foreign Corrupt Practices Act, 2012
9 OECD Anti-Bribery Convention to combat bribery of foreign officials during international commercial transactions 1997
10 The United Nations Convention against Corruption, 2003
11 Convention of Criminal Liability for Corruption, 1999
12 Recommended Practice for the Development and Implementation of Actions to Prevent and Combat Corruption, 2013 (Ministry of Labor and Social Security of the Russian Federation)

Development of this Policy used recommendations and recommended practices contained in manuals of specialized international organizations, as well as best practices in the field of compliance function building.

Обратная связь