Uralvagonzavod Research and Production Corporation OJSC

Based on public information, there is no readily available evidence of 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 company’s 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.

Based on public information, there is evidence that the company commits to the faithful execution of the commitments and principles of business ethics. The Corporate Social Responsibility policy and Code of Ethics and Corporate Conduct refer to business practice and operating in accordance with the domestic and foreign policies of the countries in which the company has operations. TI notes that the company commits to maintaining transparency and accountability in relationships with partners, fair and unbiased relationships with partners, and avoidance of unintended benefits and privileges. The company therefore scores 1. To score higher the company would need to provide further information about what these values mean to the company and demonstrate how they are translated into company policies and codes.

Based on public information, there is evidence that the Corporate Social Responsibility Policy refers to the UN Global Compact as one of several international rules governing Corporate Social Responsibility. However, the UN Global Compact website does not list the company as a participant. TI has found no further readily available evidence that the company belongs to a national or international initiative that promotes anti-corruption or business ethics.

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 to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board.

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 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 update 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.

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 evidence that the Corporate Social Responsibility policy promotes the adoption and dissemination of good business practice among suppliers, business partners and clients. The policy states that the company interacts with suppliers on the principles of mutual benefit and respect, transparency and accountability, as well as establishing fair and unbiased relationships with partners which avoid unintended benefits and privileges. However, there is no readily available evidence of specific policies or contractual terms relating to bribery and 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 evidence that the Code of Social Ethics promotes compliance with the national legislation and international norms of ethical behaviour, but the stipulations remain too general to constitute an anti-corruption policy. TI has found no further 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 that the company has 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 the company’s Corporate Code of Conduct and the Code of Social Conduct provide some regulation on conflicts of interest. However, the information available about this regulation is limited and a clear definition and examples are not provided. 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 that the company has a policy for the giving and receipt of hospitality, to ensure 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 evidence that the company has a policy of political neutrality. The company does not provide support, either directly or indirectly, to political parties, associations, and candidates for public office. The company also does not provide or transmit funds or property of political parties, associations and candidates for public office or their representatives.

Based on public information, there is evidence that the company operates a policy of political neutrality. However, there is no readily available evidence of a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company has established a number of social partnerships and provides charitable contributions as part of an education project. However, there is no readily available evidence that charitable contributions are regulated 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 the company provides anti-corruption training 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 anti-corruption training to members of the Board.

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

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

Based on public information, there is no readily available evidence that the company applies 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 to report concerns or instances of corrupt activity.

Based on public information, there is no readily available evidence that the company provides whistleblowing channels to all employees in all geographies.

Based on public information, there is no readily available evidence that the company has formal 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 well-publicised resources are 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 of a commitment to non-retaliation for bona fide reporting of corruption.