In JSC IDGC of the North-West and subsidiaries and dependent entities of the Company work on ensuring the efficiency and transparency of activities is carried out consistently.
The anti-corruption mechanisms include work on making amendments to internal documents of JSC IDGC of the North-West.
By resolution of the Board of Directors of April 17, 2012 (Minutes No.96/17) amendments were made to the Provision on the Procedure for Carrying out Regulated Purchases of Goods, Works and Services for the Needs of JSC IDGC of the North-West: in accordance with Instruction No.VP-P13-9308 of Chairman of the Government of the Russian Federation of December 28, 2011, in order to ensure the transparency of financial and business activities, including avoidance of conflicts of interest and prevention of other misuse relating to the position held, counteragents shall disclose information with respect to the entire chain of owners, including beneficiaries (in particular, final beneficiaries), confirmed by the following documents.
In 2012 serious work was performed to control the contractual work. The Company makes agreements for purchases of goods, works and services with counteragents if the following conditions are fulfilled:
- documentary confirmation of the legal capacity;
- confirmation of adequacy of labor, material, technological and financial resources for fulfillment of contractual obligations;
- confirmation of authorities on behalf of the counteragent;
- provision of information on executive authorities and owners of the organization (including final beneficiaries).
In carrying out purchasing activities participants failed to disclose the entire chain of owners, including beneficiaries (final beneficiaries), will be rejected and not be admitted to tendering.
All agreements for purchase of goods, works and services made by the Company envisage a counteragent's obligation for provision to the Company of information in case of any changes in the composition of owners and/or beneficiaries (including final beneficiaries) within 5 days of such changes in the established form, with the exception for the following agreements:
- public agreements, including agreements for provision of electric energy transmission services and agreements for technological connection;
- agreements for purchase of exchange goods on a commodity exchange in accordance with the legislation on commodity markets and exchange trading;
- other similar transactions for which the legislation does not provide an opportunity to choose counteragent;
- agreements having an administrative or business purpose.
By Order No.162 of the Company of April 6, 2012 the Mediation Board of JSC IDGC of the North-West was created and its composition was approved. The Mediation Board carries out collection and analysis of information on income, property and obligations of property nature of managers and their close relatives and identification and prevention of conflicts of interest in performance of financial and business activities of the Company and its subsidiaries.
Within the framework of measures aimed at ensuring efficiency and transparency of the Company's activities, work for collection of certificates confirming income, property and obligations of property nature of employees is carried out.
In total, as of the end of 2012 88 managers and 271 family members (359 persons in aggregate) declared their income. Taking into account hiring and dismissal of employees, as of the beginning of 2013 the declaration requirement applies to 82 managers and 246 family members (328 persons in aggregate).
The list of declarants includes:
- Director General,
- Deputy Directors General, including Deputy Directors General — Directors of branches,
- Deputy Directors General of branches,
- Directors General of subsidiaries and dependent entities of JSC IDGC of the North-West,
- Deputy Directors General of subsidiaries and dependent entities of JSC IDGC of the North-West,
- heads of departments and administrations of the executive apparatus of JSC IDGC of the North-West subordinated to Deputy Directors General,
- heads of departments, administrations and divisions of the executive apparatus of JSC IDGC of the North-West directly subordinated to Director General.
In the course of verification of certificates of income, property and obligations of property nature 3 cases of a conflict of interest were identified, which were expressed in non-provision by the declarants of information on participation of their family members in activities of counteragents. Based on results of investigations carried out the fact of a conflict of interest with the participation of officers of JSC IDGC of the North-West was confirmed but no material damage was caused to the Company.
All cases were considered at meetings of the Company's Mediation Commission.
| Measures to identify signs of affiliation | Checked/ identified | Among them facts identified with senior executives under agreements made in 2012 |
|---|---|---|
| Company's employees and their family members checked for possible affiliation with counteragents | 955/24 | 3 |
| Candidates to employment relations checked for the purpose of identification of personal or indirect connections with counteragents implying affiliation (number)/negative opinions given (number) | 486/7 | 0 |
| Potential counteragents in tendering procedures checked for the purpose of identification of affiliation (number)/negative opinions given (number) | 3,966/387 | 0 |
| Checked counteragents of JSC IDGC of the North-West and its subsidiaries under agreements effective as of December 31, 2012, the analysis of information on whom was completed/ facts of misuse identified (by officers) by managers responsible for making the transaction with the counteragent | 1,541/— | 0 |
| Decisions of tender committees checked (number) | 131 | 0 |
| Facts of lobbying identified: | 0 | |
| selection of a winner without regard to requirements of tendering documents (number) | 4 | 0 |
| unsubstantiated refusal from admission to tendering of manufacturers and their official dealers (number) | 3 | 0 |
| the price of other applicant is lower, all other conditions being equal (number) | 13 | 0 |
| the agreement with the winner of the tender provides for an advance payment (number) | 12 | 0 |
| Measures of response on identified facts of affiliation checked: | 0 | |
| tender results annulled (number) | 3 | 0 |
| agreement with counteragent terminated (number) | 1 | 0 |
| activities of the counteragent taken under control by subdivisions of the Security Department (number) | 28 | 0 |
| Company's employees excluded from among the founders (number) | 2 | 0 |
| other measures (number) | 4 | 0 |
| measures not taken (number) | 0 | 0 |
Resolutions of the Board of Directors of the Company of March 6, 2013 (Minutes No.123/21) approved the Corporate Code of Conduct of JSC IDGC of the North-West, including the Anti-Corruption Policy of JSC IDGC of the North-West.
Within the framework of implementation and compliance by the Company of the Corporate Code of Conduct it is planned:
- to create (re-profile) the Commission for Compliance with Corporate Ethics Standards and Settlement of Conflict of Interest, including the approval of the Provision of the Commission (determination of competence and procedure for functioning), etc.;
- organization of familiarization of all employees of the Company with the Corporate Code of Conduct of the Company at appointment, hiring, conclusion of employment and civil and legal agreements and annual confirmation of understanding of provisions of the Corporate Code of Conduct of the Company;
- development and implementation of the system of appropriate procedures for combating and prevention of involvement in corrupt practices;
- organization of monitoring of implemented control procedures for combating and prevention of involvement in corrupt practices and control over the compliance thereof;
- organization of the assessment of the condition of the system of combating the involvement in corrupt practices and assessment of compliance of the Company's activities with provisions of applicable laws and the Company's Anti-Corruption Policy.