Fighting fraud, corruption, embezzlement and conflict of interests

Information and communications policy of Gazprom

The concept of Gazprom’s information and communications policy was approved by Decree No. 5 of the Gazprom Management Committee dated January 27, 2005.

• It is aimed, inter alia, at the full realization of shareholders’ and investors’ rights to be informed about the Company’s activities.
• Its purpose is, inter alia, to assess the current image of Gazprom among the target groups, including shareholders, investors, potential investors as well as to find out the information and other needs of these groups.

Regulation on Information Disclosure of Gazprom was approved by the Decision of the Gazprom Board of Directors No. 2921 dated March 29, 2017. The Regulation was developed in accordance with the current legislation of the Russian Federation, regulations of the Bank of Russia, the Articles of Association of Gazprom and Gazprom’s internal documents, and with account taken of the best corporate governance practices.

Anti-corruption activities

Under the Russian Law and Gazprom’s corporate documents, the Corporate Security Service of Gazprom and corporate security services of subsidiary companies take measures to prevent and detect corrupt practices throughout Gazprom Group.

These activities are being carried out in constant cooperation with the departments performing internal audit, controlling corporate expenses, managing property and corporate relations, as well as with the law enforcement authorities of the Russian Federation.

In 2014 a Hotline was set up at Gazprom to fight with fraud, corruption and embezzlement at Gazprom Group*. The appeals received by it are scrutinized and analyzed.

On Code of Corporate Ethics

The Code of Corporate Ethics was introduced at the Company pursuant to the Decision of the Gazprom Board of Directors No. 2309 dated February 25, 2014. The document was developed with the account of the best Russian and international practices of corporate governance. It sets out the corporate values, defines the key guidelines of business conduct based on them, eliminating the conflict of interests and corruption.

With a view to prevent (eliminate/mitigate the consequences of) the instances of the conflict of interests, the Code outlines:

• restrictions related to relatives working together;
• restrictions related to employees’ participation in competitor companies, in the elected governmental bodies;
• restrictions related to receiving gifts;
• restrictions related to employees’ use of the Company’s resources for any personal purposes;

The Code determines the sequence of activities for employees in case of a conflict of interests, declares intolerance for corrupt practices, nails down the principles of environmental care, bans discrimination and sets the procedure for implementing and observance of the corporate ethics standards.

The provisions of the Code are obligatory for the employees of the Company (including all the Members of the Management Committee, Members of the Board of Directors employed with Gazprom) and legal entities controlled by the Company. The provisions of the Code are advisory for employees of the legal entities not affiliated with the Company, in which it holds a stake as well as for the employees of Gazprom’s counterparties.

The permanent Corporate Ethics Committee of Gazprom established by Gazprom’s Order No. 59 dated February 11, 2014 is responsible for arranging the work to enforce the requirements and provisions of the Code.

The Committee takes actions aimed at implementing the provisions of the Code, including those concerning relatives working together as well as relationships with competitors and counterparties. The Committee meetings review the applications received by the Committee.