The Compliance Officer at Unipro PJSC is appointed by the Board of Directors of Unipro PJSC.
Since 1 January 2017, the position of the Compliance Officer at Unipro PJSC has been occupied by Elena M. Gabdulkhaeva, Director for Corporate Management, Legal and Property Issues at Unipro PJSC.
Unipro PJSC operates a compliance hotline at +7 (909) 969 47 90 (Monday to Friday, 9:00 a.m. to 6:00 p.m.) or email@example.com for reporting any actual or potential corruption cases, which is available to both employees and partners of the Company.
Compliance constitutes an integral component of the corporate governance system at Unipro PJSC. The Company values its business reputation and corporate culture, which have been built for many years, and operates exclusively under the applicable law, in accordance with the principles of good business practices and high standards of business ethics and professional conduct.
The effectiveness of the compliance system is based on personal responsibility of each employee. That is why every employee of Unipro PJSC, regardless of the position, shall follow the rules of the Code of Corporate Conduct. It is a fundamental document which sets out the established rules that are mandatory for all employees of the Company.
The Compliance Procedure suggests a system of controls that cover activities of the Company in the following areas:
- Anti-trust law
- Securities law/rules that regulate insider trading
- Prevention of fraud, corruption, breach of the rules of conduct set out in the Code of Corporate Governance.
Unipro PJSC operates a compliance risk management system: compliance risks are assessed by the Company’s activities, resulting in the creation of a risk map indicating the probability of their realisation and a set of measures to mitigate them. Based on the results of these actions, a detailed risk assessment report is prepared with a list of practical measures and specific deadlines for their implementation.
With the participation of senior management of Unipro PJSC, a separate antitrust risk assessment is conducted on an annual basis.
Unipro PJSC believes combating the corruption to be one of the key principles of responsible business practices. The Company recognises and monitors the compliance with local anti-corruption regulations, and also implements a number of additional measures to combat involvement in corruption activities.
In 2019, the Compliance Management System at Unipro PJSC was audited by a major international auditing firm (hereinafter as “the Auditor’). The Auditor conducted an audit to verify the suitability, implementation procedure and performance of the group-wide compliance system.
As part of the performance testing, the Auditor performed end-to-end auditing and sample testing of the internal compliance system controls, the critical measures identified in the audit, as well as the measures mentioned in compliance management system (CMS) description. It included the testing of general CMS requirements and assessing compliance with them according to IDW AssS980 regarding an appropriate design of the compliance organization in terms of its size, functions (guidelines, training, communication and compliance culture) and independence; testing the effectiveness of compliance measures implemented to adequately address the risks regarding missing compliance awareness in the organization; testing the anti-corruption requirements and assessing compliance with them according to IDW AssS980 regarding an appropriate setup and effectiveness of anti-corruption measures and controls implemented, including specific risk assessment, offering specialized training for risk groups and adequate controls in identified high risk areas.
The Board of Directors of the Company reviewed and took note of the Compliance Management System Audit Report on 10 December 2019 (Minutes No. 283 of 12 December 2019).
To eliminate the risk of situations that may jeopardise the interests of the Company and its employees, the Compliance Officer pays particular attention to reports on potential conflicts of interests.
Unipro PJSC continues to work on CMS development and improvement, and will adopt a number of additional regulatory documents governing anti-corruption processes, conduct dedicated training and provide consultations to the Company’s employees on compliance with anti-corruption requirements.