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Ownership
PRIVATE
Defence revenue, USD
927m(2013)
Defence revenue, %
100% (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 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 no readily available evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. The Annual Report refers to a Code of Corporate Conduct and compliance with this, but this document does not appear to be publicly available.
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.
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, and no 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 a formal anti-corruption risk assessment procedure has been implemented enterprise-wide.
Based on public information, there is no readily available evidence of 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 make 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 that there is evidence of a policy on procurement, which emphasises the need for equality, fairness, non-discrimination and genuine competition. However, there is no explicit reference to bribery and corruption and no information on the consequences of breaches to this policy.
Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.
Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.
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.
Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.
Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company.
Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties.
Based on public information, there is no readily available evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.
Based on public information, there is evidence that a policy on potential conflicts of interests applies to the Board of Directors. The Regulations on the Board of Directors states that the Board must refrain from actions that may lead to conflicts of interests and that matters in which an individual has a personal interest must be disclosed to the Board. However, TI has found no further information on this policy and there is no publicly available evidence that this policy also applies to all employees.
Based on public information, there is evidence that a policy on the receipt of gifts applies to the Board of Directors. The Regulations on the Board of Directors states that Board members are prohibited from accepting gifts or benefits offered by third parties if they are not symbolic tokens in accordance with generally accepted rules or courtesy or souvenirs at official events. However, TI has found no further information on this policy and there is no publicly available evidence that this policy also applies to all employees.
Based on public information, there is evidence that a policy on the receipt of benefits, which may include hospitality, applies to the Board of Directors. The Regulations on the Board of Directors states that Board members are prohibited from accepting any gifts or benefits offered by third parties if they are not symbolic tokens in accordance with generally accepted rules or courtesy or souvenirs at official events. However, TI has found no further information on this policy and there is no publicly available evidence that this policy also applies to all employees.
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. However, TI notes that the company does contribute charitable donations to various groups.
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 evidence that Board members must declare conflicts of interest, as outlined in the Regulations on the Board of Directors. However, TI has found no further information on this process and there is no publicly available evidence that this policy also applies to all employees.
Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.
Based on public information, there is no readily available evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.
Based on public information, there is no readily available evidence that the company has whistleblowing channels.
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.
Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.
Based on public information, there is no readily available evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption.
Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board publishes a statement supporting the ethics and anti-corruption agenda of the company.