Control bodies
| Control body | Key roles | Key 2018 results |
| Internal Audit Unit | - Internal audit based on a risk-oriented approach and best practices
- Independent assistance in the enhancement of risk management, internal controls, and corporate governance
- Ensuring efficient operation of the Ethics Hotline
| - Executed the audit action plan, achieved economic benefit
- Provided recommendations to increase risk manageability, and proposals to receive additional income and cut costs
- Began implementing the continuous audit model developed earlier
- Integrated IT solutions into audit
|
| Risk Management divisions | Building, monitoring, and maintaining the risk management system (RMS) | - Implemented projects to automate the RMS:
- Online risk reports for managers
- Risk indicator dashboard for business processes (pilot)
- Initiated changes in the procurement management process following the RMS automation development projects
- Adopted simulation in risk assessment
- Included risk modelling and risk response measures verification procedure in the Regulations on the Corporate Project Management
- Initiated the Single Point of Contact for Project Management to obtain information on the project management and product launch risks
- Approved the Risk Management Programme
- Approved the Action Plan to mitigate the risks of business interruption due to sanctions
|
| Asset Protection Department | - Corporate culture development in terms of anti-corruption, prevention of embezzlement and the conflict of interest, and compliance with ethical standards
- Analysing and monitoring the activities of the Company and its subsidiaries and affiliates related to asset protection
- Maintaining a hotline and an anti-corruption portal
| - Launched an automated system to resolve conflicts of interest
- Developed and implemented the Company’s 2018 compliance programme
- Held in-person and remote compliance trainings
- Introduced anti-corruption programmes at 30 subsidiaries and affiliates
|
| Dedicated officials responsible for the implementation of internal controls to counter money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction | - Protecting the Company from criminally obtained incomes
- Mitigating the risk of money laundering and the financing of terrorism
- Monitoring compliance with the requirements for subscriber identification
- Identifying and terminating criminal/dubious activities
| - Appointed dedicated officials responsible for internal controls in all macroregional branches
- Created teams headed by security directors in all regional branches
- Appointed employees responsible for subscriber identification
- Automated subscriber inspection for invalidated passports and engagement in extremism and terrorism
- Assessed the risk of legalisation of criminally obtained incomes by customers
- Arranged for trainings on countering money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction
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| Internal Control Unit | Assisting the top management in building an efficient internal control system (ICS) | Reviewed the ICS across the key processes and the Company’s macroregional branches to develop recommendations and take actions to enhance its efficiency |
| Audit Commission | Monitoring financial and business operations between General Shareholders’ Meetings | Audited the financial and business performance of the Company in 2018, including the annual report and annual accounting statements |
Conflict of interest management
In June 2018, Rostelecom launched an automated system to resolve conflicts of interest. Any Rostelecom’s employee with a conflict of interest, as well as employees in positions exposed to a higher corruption risk regularly complete electronic declarations. Links to complete the declarations are sent automatically, thus excluding the human factor from mandatory disclosures.
For 2019, we have scheduled the integration of the conflict of interest management system with automated internal and external systems, as well as the expansion of the system’s functions.
Anti-corruption efforts development at PJSC Rostelecom’s subsidiaries and affiliates
In 2018, Rostelecom developed anti-corruption processes at 30 subsidiaries and affiliates in which it has an effective interest of over 50%.
