Corporate ethics
Ensuring compliance with corporate values
The Company has in place the Code of Corporate Ethics of Gazprom
Code of Ethics:
- defines the corporate values, as well as the guiding principles of business conduct based thereon;
- sets out the notion of the “conflict of interest”;
- stipulates the prohibitions and restrictions designed to prevent situations of a conflict of interest;
- proclaims zero tolerance to corruption;
- specifies the requirements to the personal conduct of employees;
- establishes the course of action to be taken by employees in the event of a conflict of interest.
Corporate values of Gazprom
Application of the Code of Ethics:
Mandatory
- Employees of Gazprom
- Employees of legal entities controlled by Gazprom (until such controlled entities develop their own codes of corporate ethics)
- Members of the Gazprom Board of Directors
Advisory
- Legal entities not controlled by Gazprom in which it owns a stake
- Individuals employed by Gazprom under civil contracts
- Counterparties of Gazprom
All legal entities controlled by Gazprom shall, on the basis of the Code of Corporate Ethics of Gazprom, without changing it but at liberty to complement it, develop and approve their own codes of corporate ethics to be applied to their respective employees.
Counterparties are engaged in the single system of corporate values adopted across the Gazprom Group through the introduction of a clause on the Code of Corporate Ethics into the contracts signed with them.
Training course “Corporate ethics at Gazprom for suppliers”
Conflict of interest is a situation when an employee's personal interests compromise or may compromise the fair and impartial performance of his/her job duties and when a contradiction arises or may arise between the personal interests of an employee and the lawful interests of the Company where such contradiction may prejudice the lawful interests of the Company . Employees shall avoid any situations where a conflict of interest may arise.
Penalties for the violation of the norms of ethics:
- public reprimand;
- public censure;
- cancellation of some or all bonuses pursuant to the Company's internal documents;
- disciplinary measures, if the employee's actions (inaction) qualify as a disciplinary offense.
All employees receive a special training course on the implementation of the Code of Ethics and take a subsequent knowledge test at least once every three years
Number of Gazprom Group employees who received training on corporate ethics norms, 2019–2023, persons*
* The value of this indicator is determined by the employee training frequency (once every three years) and personnel movements across the Gazprom Group
Corporate Ethics Commission of Gazprom
The Corporate Ethics Commission of Gazprom (hereinafter also referred to as the “Corporate Ethics Commission”) plays a key role in ensuring that the corporate values are duly implemented. Its activities are governed by the Regulation on the Corporate Ethics Commission of Gazprom approved by Gazprom's Order No. 59 dated February 11, 2014, as amended from time to time.
Legal entities controlled by Gazprom have their own local corporate ethics commissions.
The main task of the Corporate Ethics Commission is to organize the activities aimed at the implementation of the requirements and provisions of the Code of Ethics, ensuring a comprehensive approach to and coordination of relevant efforts across the Company's structural units.
Functions of the Corporate Ethics Commission:
To clarify to employees the provisions of the Code of Ethics and the application thereof.
To consider situations where there is a conflict of interest and provide proposals regarding the measures to avoid, resolve or limit the conflict of interest and/or its consequences for the purpose of protecting the Company's interests.
To consider situations where other violations of the Code of Ethics take place and provide proposals regarding the elimination (prevention) of such violations.
To make suggestions for the relevant manager of Gazprom to resolve to apply the appropriate penalties or issue a written consent (in the cases where a written consent of the manager of Gazprom is required under the Code of Ethics).
To develop proposals regarding the measures to achieve a more efficient implementation of the corporate values.
The Corporate Ethics Commission of Gazprom can be addressed via:
Mailing address
BOX 1255, St. Petersburg, 200961, Russian Federation
Hotline
Policy for legal protection of whistleblowers
Pursuant to the Code of Corporate Ethics of Gazprom
Pursuant to the Regulation on the Hotline for fighting fraud, corruption, and embezzlement at the Gazprom Group
As a follow-up to the provisions of the above norms, other internal documents are also developed and adopted at Gazprom.
FAQs
On the occasion of a public holiday, a gift has arrived for an employee. However, the gift is packaged, which makes it impossible to assess its value without damaging the packaging. What should the employee do with the gift?
The Company imposes restrictions on the acceptance of gifts. Employees of the Company are not allowed to accept gifts offered by any third parties:
- for any actions (inaction) related to the work at the Company;
- with a value of over RUB 3,000;
- in cash or cash equivalents;
- in the absence of any clear and generally acceptable reason for such gift.
Any unauthorized gifts shall be declined. Therefore, the employee can do the following. First of all, the employee shall assess the relationship between him/her and the gift-giver (determine whether the gift-giver is a Gazprom Group company or a third-party company; whether there is a valid contract signed with the gift-giver; whether it is possible for the employee (taking into account his/her position in the Company) to have an influence on the conclusion of a contract between the Company and the gift-giver and/or influence the decisions made by the Company in connection with the existing contract; etc.).
The employee can return a packaged gift without unpacking it.
The employee can also unpack the gift and assess its possible value on the basis of publicly available information. If the gift is an unauthorized one, it shall be returned to the sender.
When in doubt or puzzled about the value and appropriateness of a gift, the employee shall seek clarification from the Corporate Ethics Commission.
Can an employee have his/her relative as his/her immediate superior at work, provided that this situation has been preliminarily approved by the corporate ethics commission of the relevant company? Do the provisions on relatives working together apply to the relations that arose before the adoption of the Code of Corporate Ethics?
The Company imposes restrictions on the instances of family relationships in the workplace. Situations where relatives in executive roles serve as immediate superiors to their relatives in subordinate roles are not allowed. Such situations in the workplace are prohibited.
Indirect supervisory relationship between relatives is allowed, but only by decision of the Corporate Ethics Commission. Therefore, each case of an indirect supervisory relationship between relatives working together shall be considered by the Corporate Ethics Commission, regardless of whether such conflict of interest arose before or after the adoption of the Code of Corporate Ethics.
Can an employee conduct entrepreneurial activities (e.g. be an individual entrepreneur) or work concurrently for another employer?
As per the Code of Corporate Ethics, employees shall not conduct any entrepreneurial or other commercial activities (including participation in the equity or management of legal entities) by taking advantage of their position at the Company, including by using the business connections and capabilities of the Company.
The Company's assets and resources include the following:
- any movable or immovable property, including cash and securities;
- intellectual property;
- working time of employees (human resources).
Each employee shall use the Company's resources available to him/her with maximum efficiency and for work-related purposes only.
Therefore, will not be a violation of the norms of corporate ethics to conduct entrepreneurial activities concurrently with working at the Company, provided that the employee complies with all of the above requirements of the Code of Corporate Ethics and such concurrent work does not give rise to other conflicts of interest (i.e. situations when an employee's personal interests compromise or may compromise the fair and impartial performance of his/her job duties and when a contradiction arises or may arise between the personal interests of an employee and the Company's lawful interests where such contradiction may prejudice the Company's lawful interests).
It must also be taken into account that the employees of the Company shall not, without the written consent of the Company's relevant manager, work or hold any positions in the management bodies of the Company's competitors.
Whom shall employees of Gazprom's subsidiaries contact if a conflict of interest arises in connection with work at a subsidiary?
If a conflict of interest arises in connection with work at a subsidiary, employees of subsidiaries shall address the corporate ethics commission of the corresponding subsidiary.
The Corporate Ethics Commission of Gazprom considers inquiries and information from employees of the Company-controlled entities concerning their work at such controlled entities if there is no local corporate ethics commission established at the corresponding controlled entity or the activities of such commission are temporarily suspended at the time. However, the Corporate Ethics Commission of Gazprom has the right to accept for consideration any inquiries and information from an employee of a controlled entity and review such submissions on their merits.
Gazprom's reports
Gazprom Annual Report 2023
Corporate Ethics and Anti-corruption Efforts
Social Impact Report 2023
Corporate Ethics and Anti-corruption Efforts