Gorky Automobile Plant

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values representing some high standards of business conduct, including honesty, integrity and trust. However, these values are not explained in detail, nor is it clear how these values are translated into company policies. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. TI notes that reference is made to the Chief Ethics Commissioner. However, it is not clear what the position entails, nor is the individual named.

Based on public information, there is no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. TI notes that the Code of Ethics makes reference to risk analysis and management, but evidence does not suggest corruption is an identified risk.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. The company affirms to always comply with its obligations and expects commitments from its partners. However, it is unclear whether this refers to countering corruption.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. The company affirms to always comply with its obligations and expects commitments from its partners. However, it is unclear whether this refers to countering corruption.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. TI notes there is a very brief statement that gifts should not be received that could be construed as a bribe. However, this is inapplicable as it is unclear and insufficiently strong.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the company’s Code of Ethics is easily accessible to Board members, employees and third parties. The Code of Ethics is available on the company’s website in Russian. To score higher the company would need to provide evidence that the Code of Ethics is available in at least one other language.

Based on public information, there is evidence that the company’s Code of Ethics is somewhat understandable to Board members, employees and third parties. The Code does not describe company policies in detail and is not written in highly comprehensible language. Therefore the company scores 1.

Based on public information, there is evidence that the company’s Code of Ethics explicitly applies to employees. The company therefore scores 1. To score higher the company would need to provide evidence that the Code of Ethics also applies to Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest applicable to employees. The policy defines and prohibits conflicts of interest. The company therefore scores 1. To score higher the company would need to provide evidence that this policy also applies to Board members and evidence of examples of conflicts of interest.

Based on public information, there is some evidence that the company has a policy for the receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company prohibits employees from accepting gifts from third parties that may be construed as a bribe. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of a gift and/or the requirement for senior management if a value threshold is exceeded, for both giving and receiving gifts.

Based on public information, there is some evidence that the company has a policy for the receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company prohibits employees from accepting gifts from third parties that may be construed as a bribe. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of hospitality and/or the requirement for senior management if a value threshold is exceeded, for both giving and receiving hospitality.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is evidence that the company prohibits direct and indirect participation in political parties.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies. TI notes that the company’s Code of Ethics contains a statement that the company does not make any attempts to influence the decisions of the state authorities or their representatives. However, this is not assessed to constitute a clear policy on engagement in lobbying activities.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI notes that the company has a social policy and priorities that aim at developing social programmes and support for the community. However, there is no policy or statement regulating such activities and programmes against undue influence or corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme on its Code of Ethics, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence of a specific anti-corruption training module.

Based on public information, there is evidence that the company provides training on its Code of Ethics, which includes an anti-corruption policy, to all employees.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees found to have engaged in activities that violate the Code of Ethics and respective legislation and regulations. The company therefore scores 1. To score higher the company would need to provide evidence that it also has an explicit commitment to apply disciplinary procedures to Board members and Directors of the company who violate the Code of Ethics.

Based on public information, there is evidence that the company allows employees to report concerns or instances of suspected corrupt activity to the Group’s Chief Ethics Commissioner. Employees can contact the Chief Ethics Commissioner via a Hotline that facilitates anonymous reporting. The company therefore scores 1. To score higher the company would need to provide evidence of an independent source for employees to report to.

Based on public information, there is evidence that across geographies, all employees have access to the Group’s Chief Ethics Commissioner. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one reporting channel.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

Based on public information, there is evidence that employees can receive help and advice on corruption-related issues from the Group’s Chief Ethics Commissioner.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this commitment.