Business Ethics and Anti-Corruption
102-16
Metalloinvest places a particular emphasis on anti-corruption and anti-fraud, as well as creating an ethical culture. Creating a system of universal compliance control is a priority for Metalloinvest that ensures sustainable business development. The Company consistently updates and improves anti-corruption procedures while integrating them into all business processes in which there is a risk of corruption violations. Combatting corruption and adhering to business ethics are an essential part of the Company’s corporate culture.
The Company has an Anti-Corruption Policy and a Code of Corporate Ethics, which formalise issues concerning honest and ethical business, a zero tolerance attitude towards discrimination or corruption, the rules for doing business, and internal and external engagement with the Company’s employees. Along with the general corporate policies, each business unit adopts in-house internal documents that regulate compliance with anti-corruption measures.
In addition to the policies, the Company has integrated a number of anti-corruption mechanisms, in particular the following.
The briefing of employees is a formal procedure used to familiarise all the Company’s employees with fundamental regulatory acts upon hiring as well as when such acts are updated. In addition, the Company made preparations in 2018 to launch training courses using the distance learning system in 2019. The training courses will primarily consist of videos providing information about the Company’s rules and principles for combatting corruption. These training courses will become an additional tool to consolidate the knowledge and skills of employees regarding anti-corruption.
205-2
In 2018, 100% of employees – senior executives, middle managers, managers, specialists, employees, and workers – were briefed about the provisions of anti-corruption policies. All business partners (including employees of contracting organisations), which includes more than 270,000 people, were also briefed.
In addition to the mandatory briefing for all of the Company’s employees, Metalloinvest provides specialised training for employees whose professional activities directly involve managing corruption risks.
205-2
In 2018, three of the Company’s employees were trained at the International Compliance Association (ICA) and received the relevant certificates. In the next reporting period, two more employees will be trained and certified.
102-17
The Company continued to operate an anti-corruption hotline in 2018. In addition to a dedicated telephone line and email address, internal and external stakeholders were also able to send their requests through Viber and WhatsApp and also fill out a special form on the Company’s corporate portal, which was an innovation in the reporting period.
205-3
During the reporting period, the hotline received 120 calls, which resulted in 31 cases of misconduct being confirmed as a result of checks. Violators were subject to disciplinary measures in accordance with existing legislation and the Company’s internal documents. In addition, revisions and changes were made to the business processes in which the violations occurred.
Metalloinvest welcomes the practice of whistleblowing, guarantees all applicants confidentiality and a lack of retaliation, and also investigates each inquiry.
Data from Ural Scrap Company was also included in the calculation of cases of misconduct.
As part of the anti-corruption expert evaluation that all draft contracts must undergo, procedures are examined in terms of their transparency and to make sure there are no unreasonable exceptions.
Anti-corruption monitoring involves the Company conducting an independent assessment of corruption risks by tracking the effectiveness of steps that have been taken. Part of the procedure is a quarterly report given by the Security Director to the Company’s CEO on the results of the evaluation with suggestions for improving anti-corruption activities.
205-1
In 2018, an assessment of corruption risks was carried out at all four of Metalloinvest’s units (plants). Based on the monitoring results, all mechanisms for managing anti-corruption activities proved to be effective, which enabled the Company to join the Anti-Corruption Charter of Russian Business in November 2018.
205-3
There were no contract terminations or nonrenewals with business partners due to corruption violations in the reporting period. There were also no cases of legal proceedings against the Company or its employees based on involvement in violations of anti-corruption legislation.
In the future reporting period, the Company is planning to prepare for an external audit for compliance with the requirements of ISO 37001:2016 Anti-bribery management systems.
