- A
- B
- C
- D
- E
- F
Ownership
PUBLIC
Defence revenue, USD
819m (2013)
Defence revenue, %
38% (2013)
Country
RUSSIA
Internal information
NO
Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrates 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 some evidence that the company publishes a statement of values representing high standards of business conduct. However, other than openness, honesty, and transparency these do not cover the values sought by the question and it is unclear how these values translate into company policies and codes. 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. The company subscribes to the principles of the UN Global Compact as detailed in its Policy and Memorandum on Corporate Social Responsibility, as part of the parent company’s policies. However, the membership seems to be inactive at present. Also, TI notes that the parent company Sistema JSFC is a member of the UN Global Compact. However, the company’s recent status is non-communicating as it failed to submit its Communication on Progress.
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.
Based on public information, there is no readily available evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. There is some evidence of an annual process of monitoring and reporting of the Corporate Social Responsibility Policy, but it is unclear who facilitates this.
Based on public information, there is no readily available evidence that there is a formal, clear, written plan 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, whilst the company undertakes risk management, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure.
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.
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. TI notes a company order which regulates the register of unethical suppliers, but there is no evidence to suggest this includes a focus on 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. The company has made a statement supporting UN Global Compact policies, but this is not considered a comprehensive anti-corruption policy and the commitment to the UN Global Compact has not been renewed by the parent company. The company does refer to an anti-corruption policy in the Annual report, together with other documents on fraud. However, TI is unable to access them publically.
Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.
Based on public information, the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. The Code of Ethics and the Corporate Social Responsibility Policy are available on the company’s website in Russian, with evidence suggesting the company only operates in Russia.
Based on public information, there is evidence that the company’s ethics and corporate social responsibility policy is somewhat understandable. The company’s anti-corruption policy in its entirety is not publicly available and the various documents that refer to ethics and anti-corruption are not extensive. The company therefore scores 1.
Based on public information, there is evidence that the company’s ethics and corporate social responsibility policy applies to all employees and members of the Board.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest. However, the policy is assessed to be limited, only providing examples for Directors and and Senior Officials. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery.
Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.
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 no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.
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.
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.
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 no readily available evidence that the company has a training programme that explicitly covers anti-corruption.
Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.
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 some evidence that the company has a formal process by which employees declare conflicts of interest. Employees are instructed to report conflicts of interest to their direct supervisor or the Board of Directors. To score higher the company would need to provide evidence that all conflicts of interest are reported to an independent department, rather than a direct supervisor.
Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees and Directors who violate its Code of Ethics and related policies.
Based on public information, there is evidence that the company has a hotline for employees to report concerns or instances of suspected corrupt activity. The hotline is accessible by email or phone. The company therefore scores 1. To score higher the company would need to provide evidence of at least one reporting channel that is externally operated and facilitates anonymous reporting.
Based on public information, there is evidence that across geographies, all employees have access to the ‘hotline’, accessible by phone and email. The company therefore scores 1. To score higher the company would need to provide evidence of at least one other reporting channel that all employees have access to.
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, and that whistleblowers are treated supportively. The company conducts surveys and “360 degree” assessments, but it is unclear whether this relates to the whistleblowing process.
Based on public information, there is some evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. Employees may address questions on compliance with the Code of Ethics to the Board of Directors via the Corporate Secretary. However, it is unclear whether these parties are trained for the advisory job. The company therefore scores 1.
Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of breaches of the Code of Ethics. 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 policy.
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.