Compliance and anti-corruption

Compliance is an integral part 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 Unipro PJSC.

The Compliance Procedure suggests a system of controls that cover activities of the Company in the following areas:

• antitrust regulations;
• securities law/rules that regulate insider trading;
• prevention of fraud, corruption, violations of the rules of conduct envisaged by the Code of Corporate Governance.

The Code of Corporate Conduct for training (e-learning) once every two years, as well as upon hire of new employees.205-2

Unipro PJSC has a compliance risk management system: compliance risks are assessed for the Company’s activities, resulting in the creation of a risk map with the degree of probability of their materialisation and a set of measures to mitigate them. Further, based on the results of these actions, a detailed risk assessment report is prepared with a list of practical measures and specific deadlines fortheir implementation.

In addition, with the participation of senior management of Unipro PJSC, a separate antitrust risk assessment is conducted on an annual basis. In 2020, the Company approved a new Antimonopoly Policy, which describes the major antitrust violations and gives recommendations to employees on how to prevent it.

Unipro PJSC believes combating the corruption to be one of the key principles of responsible business practices. The Company carries out its activities in strict compliance with the requirements of the anticorruption laws of the Russian Federation, recognises the importance of anti-corruption procedures and controls compliance therewith. For this purpose, Unipro takes actions to identify, prevent and combat corrupt practices, provides support to law enforcement authorities in the identification and investigation of facts of corruption, takes necessary measures to keep and transfer documents and information on corruption offences to law enforcement authorities.

In 2020, the compliance officer received more than 10 applications from the Company’s employees, including relating to potential conflicts of interest and participation in events and congratulations of partners in connection with some memorable dates. Following the review of these applications, all situations were assessed in terms of compliance with the principles of the Code of Corporate Conduct of Unipro PJSC, and the employees were offered the correct action plan.

To avoid the 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. At the same time, the Company welcomes the continuity of generations and the preservation of the dynasty of power engineers. Thus, Unipro is of the opinion that each potential conflict of interest is unique and should be considered separately, but additional control measures can be taken.