Anti-corruption policy

The Anti-Corruption Policy Standard applies to all areas of the Company’s business. The Company’s position in the field of anti-corruption is public.

The Company has an Anti-Corruption Policy adopted by the Board of Directors of PJSC TATNEFT in 2014 and approved the relevant corporate standard, which sets out the basic principles aimed at preventing corruption.

Basic principles, rules and procedures aimed at preventing corruption

The rejection of corruption and the prohibition of corruption

The Company’s activities are based on the prevention of corruption in all forms and manifestations. All employees, members of the Company’s management bodies and other persons acting on behalf of the Company or in its interests are prohibited, directly or indirectly, personally or through some kind of mediation, to participate in corrupt activities regardless of the business practices in a particular country or region.

TATNEFT does not allow corrupt actions, including the manifestation of a conflict of interest, both in relation to representatives of the state, public formations, organizations of any form of ownership, political figures and other third parties, and in relation to the Company’s employees, in any way, including through abuse official position in order to extract any personal gain.

The inevitability of punishment

The company investigates all reasonably justified reports of violations of proper procedures to counter involvement in corrupt activities and prosecutes the perpetrators without regard to their position, duration of work, status in the Company and other relationships with it in accordance with applicable law and local regulations of the Company. The company makes all possible reasonable and legal efforts for the fastest possible suppression of violations. The company gives publicity to persons who have violated the requirements of the applicable law and the Anti-Corruption Policy.

Legality

In carrying out their activities, the company and its employees are obliged to comply with the norms of the Russian anti-corruption legislation, as well as the applicable norms of foreign anti-corruption legislation if they enter into legal relations that are subject to such legislation.

The tone of top management

Senior officials of the Company, including members of management bodies, heads of departments, divisions and other departments of the Company, must declare an uncompromising attitude towards all forms and manifestations of corruption at all levels, demonstrate, implement and observe it in practice.

Consistency and proportionality

The company develops and implements a system of proper procedures to counter and prevent involvement in corrupt activities. The company seeks to make the procedures as transparent, clear, achievable and reasonably consistent with the identified risks.

Due diligence principle

The Company monitors and checks counterparties and candidates for positions in the Company before making a decision to start or continue business relationships or recruitment for their reliability, rejection of corruption and the risk of conflict of interest.

Informing and learning

The company informs and explains the principles and norms of the applicable legislation, the Anti-Corruption Policy and other local regulatory documents in relation to countering involvement in corruption activities, including training employees in the basics of countering involvement in corruption activities and explaining its policy in this area to counterparties.

Monitoring

The company constantly monitors the implemented procedures to counter and prevent involvement in corruption activities and monitors their compliance. The Company periodically makes an independent assessment of the state of the system for countering involvement in corruption activities, as well as an assessment of the compliance of the Company’s activities with the applicable laws and the Anti-Corruption Policy. The results of the evaluation are reported to shareholders and the public in an annual report, press releases and other informational materials.

Improving the system of proper procedures

Reports of violations of the Anti-Corruption Policy can be transmitted in the following ways:

to your immediate or superior supervisor;
to the Company’s 24-hour hotline;
to law enforcement.

Protect the interests of workers

No sanctions can be applied to an employee for:

failure to engage in corrupt activities, even if as a result of such a refusal, the Company incurred losses, lost profits, and commercial and / or competitive advantages were not obtained;
bona fide reporting of alleged violations, acts of corruption, other abuses, or the lack of effectiveness of existing control procedures.

If an employee of the Company or another person provides knowingly false information or tries, using anti-corruption procedures, to obtain personal benefits contrary to the interests of the Company or applicable law, then such a person can be held liable in accordance with the current legislation and local regulatory documents of the Company.

A responsibility

Responsibility for the implementation of the anti-corruption policy of the Company and combating corruption in all areas of the Company’s activities is ensured by the Economic Security, Information Protection, Civil Defense and Emergency Situations Department of PJSC TATNEFT.

All employees, regardless of their position, are responsible, as provided for by the current legislation of the Russian Federation, for observing the principles and requirements of the Anti-Corruption Policy, as well as for the actions (inaction) of their subordinates who violate these principles and requirements. Persons guilty of violating the requirements of the Anti-Corruption Policy may be brought to disciplinary, administrative, civil or criminal liability on the initiative of the Company, law enforcement agencies or other persons in the manner and on the grounds provided for by the legislation of the Russian Federation, the Articles of Association of PJSC TATNEFT, local regulations and employment contracts.

Regular assessment of risks of involvement in corrupt activities

The company identifies, evaluates and periodically reevaluates the corruption risks characteristic of its potentially vulnerable business processes. When identifying and assessing risks, the Company takes into account the fullness of information about its activities and plans, including investment and strategic ones, available at the time of the assessment and reassessment.

The regulatory framework of the company’s anti-corruption activities

Legislation of the Russian Federation.
The Code of Corporate Governance of the Tatneft Company.
Regulations on the Anti-Corruption Policy of TATNEFT Company.

Results of anti-corruption programs implementation

In the reporting year, the Company held events to identify and assess corruption risks in conjunction with the Internal Audit Department and the Human Resources Department. As a result of the measures taken, certain facts of violations were revealed and appropriate measures were taken.

Hotline information system

Anti-corruption policy

Basic principles, rules and procedures aimed at preventing corruption

The regulatory framework of the company’s anti-corruption activities

Results of anti-corruption programs implementation

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