Anti-corruption activities

Gazprom Neft is committed to ethical and responsible business conduct. The relevant statement is included in the Gazprom Neft Corporate Code of Conduct.

The company has a policy of zero-tolerance towards any forms of corruption, including extortion and bribery.

Gazprom Neft has approved an Anti-Fraud and Anti-Corruption Policy and made it publicly available. This is a fundamental internal anti-corruption directive for the company and its subsidiaries.

This Policy defines fraud and other terms related to fraud prevention; based on this Policy, the company’s senior management sets a single ethical standard of zero tolerance towards any type and form of corruption. The Policy outlines methods and procedures used by the company to combat fraud and corruption; these include a hotline, official investigations and prosecution with respect to identified cases of fraud.

Special attention is paid to corruption risks specific to the oil industry. The Policy includes a section on the company’s business processes most exposed to fraud: interacting with officials, accepting and making gifts, entertainment expenses, charity and sponsorship, and financial arrangements with third parties.

The Anti-Fraud and Anti-Corruption Policy also stipulates that company employees must be trained in the zero-tolerance approach to fraud, and in the basics of applicable legislation.

The Deputy CEO for Security and the head of the Internal Audit and Risk Management Directorate report regularly to company executives on anti-fraud and anti-corruption issues.

Investigation of reports received via the company hotline revealed no instances of corruption in 2019Under the applicable legislation, investigations into corruption fall within the jurisdiction of law enforcement authorities. Therefore, if any evidence of corruption is found, the relevant materials must be handed over to law enforcement authorities. The findings of investigation of reports received via the company hotline in 2019 showed no need to contact law enforcement authorities..

The following courses have been developed and are used in the corporate training system: Preventing and Combating Corporate Corruption; Corruption Prevention; Combating Corruption and Fraud. These courses are mandatory for all employees newly hired by the company.