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Anti-corruption PolicyAs a company which is committed to transparency in our operations, Rusneftegaz abhors corruption in all its forms and manifestations, as we believe that all violations of the law present a threat to the ongoing growth of our organization. This comprises any abuses of authority, power or official position by a member of our workforce, contrary to the legitimate interests of our corporation. For example, this could entail extorting, giving, mediating, offering, promising, or receiving bribes, or making any payments to simplify administrative formalities on behalf of another entity. In spite of the fact such illegal transactions are typically arranged in exchange for money, benefits can also take fruition in the form of other valuables, property, provisions, rights or services for the perpetrator or an intermediary. Due to the severity of these crimes, our board of directors performs routine assessments regarding the inherent exposure to such impropriety in both the industries and jurisdictions where we conduct our business, and has undertaken decisive action to defend against such threats. Consequently, we have implemented a series of internal regulations designed to eliminate all such legal and reputational risks to our enterprise, and combat any contraventions of such policies in due course. For instance, we currently employ a comprehensive code of ethics, which has been developed over the past two decades in accordance with the best practices from around the world. Compliance with these rules is mandatory for all our staff, without exception, with our management routinely terminating the employment of any individual found in breach of these guidelines.
Although the previously cited matters pertain solely to the behavior of our personnel, we have also instigated a number of additional measures to improve the integrity of many of our corporate structures and mechanisms. By way of illustration, all our employees are strictly prohibited from representing our company or any of our subsidiaries in any proceedings beyond their contractual remit without implicit authorization from their superior. As a result, since the beginning of 2016 all our asset acquisitions have been completed via open and efficient procurement procedures to prevent such malpractices from occurring. To further mitigate the issue, we now also maintain a detailed register of declared conflicts of interest for our senior leadership, with these records allowing our arbitrators to respond to such issues appropriately, including dismissing the staff involved if necessary. At a minimum, all such affairs will be logged in our files for future reference, in conjunction with any other noteworthy breaches or potential infringements of our protocols. Unless the culprit is observed committing a transgression by one of their contemporaries, the majority of reports of such misconduct are disclosed to us via our hotline, which provides all individuals with the opportunity to inform us of all types of wrongdoing. Whilst this arrangement has been primarily created to collect and process the data pertaining to various felonies and misdemeanors, it is also crucial for not merely sustaining our high ethical principles, but trust in Rusneftegaz as an organization.
Hence, we are particularly interested in receiving any details in relation to a range of serious criminal offenses, not limited to but inclusive of indications of fraud, larceny and the embezzlement or misappropriation of our properties. We take a zero-tolerance approach to any crimes committed against us, be it any loss of or damages to our material assets, or theft of our physical or intangible goods. Whereas all such acts are liable for prosecution, Rusneftegaz similarly refuses to accept the misuse of our confidential proprietary information, and any corresponding infractions should be communicated to us as soon as possible. We also have concerns in connection with the acceptance or payment of any bribes, kickbacks or payoffs, in addition to any other activities that may be detrimental to our interests or wider reputation. This includes contraventions of our internal regulations or business standards, namely defying the norms of fair competition or conflict of interest within our corporation. For instance, this may entail contravening our tendering rules, purposefully inhibiting this system for the benefit of a third party, or any actions where an employee exceeds their designated authority without approval. Despite the fact all these aforementioned deeds are heinous by their very nature, it also comprises the commissioning of these acts on behalf of another entity. We are also wary about misdemeanors executed with no premeditation or nefarious intent. For example, we remain vigilant regarding noncompliance with environmental or industrial safety legislation, violations of applicable labor laws, and any similar safeguarding failures with respect to our holdings or personnel.
To help us prevent such gross misconduct, we invite all individuals who observe any transgressions to contact us via any of the means listed below. We wholly guarantee the confidentiality of any intelligence transmitted to us in this fashion, pursuant to all relevant data protection laws, in conjunction with providing assurances about upholding the anonymity of the whistleblower involved. All reports are processed by our anti-corruption officer, who acts independently of our leadership hierarchy and reviews all cases in the fullness of time. As a company, we undertake extensive measures to ensure that none of the suspects can interfere with this process, or discover the original source of the allegations. During each assessment, one of our officials shall garner the collated evidence, and objectively verify its authenticity. The conclusions will then be drawn on the basis of established facts, and will then be submitted to the appropriate managers, who will ultimately decide the most suitable course of action. In certain circumstances, we may allow anyone implicated to appeal any sanctions received if there are sufficient grounds to do so. Be that as it may, this is exceedingly rare, as all our inquiries are conducted in a diligent and thorough manner. Nonetheless, in such a situation the accused may be able to petition directly to our board of directors, who have the power to determine their own resolution. However, whilst we customarily update the informant following the completion of our probe, we may elect to open a new investigation if we rule that the complaints are fabricated. If this were to occur, those found to have manufactured these lies may be subject to charges of slander under the terms of the Criminal Code of the Russian Federation.
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