Business Ethics and Human Rights

Business ethics

PJSC Rostelecom strictly complies with all applicable laws, is guided by the principles of transparency and accountability, engages with external and internal stakeholders in an ethical manner, and is committed to fair business practices.

Rostelecom’s Code of Ethics conforms to the highest standards of business ethics and underpinned by its corporate values of expertise, responsibility, innovation, openness, and continuity. Rostelecom’s anti-corruption efforts are carried out under the applicable Russian laws, including Federal Law No. 273-FZ On Countering Corruption dated 25 December 2008.

Corruption threatens the rule of law and adversely affects the United Nations Sustainable Development Goals; hence, we pay special attention to countering corruption and bribery.

Code of Ethics

Legal compliance, integrity, openness, privacy, and engagement are the key principles of PJSC Rostelecom’s Code of Ethics.

Any employee of the Company can report violations of the Code of Ethics to a dedicated e-mail address: ethics@rostelecom.ru.

Rostelecom cooperates with the government to help justice and law-enforcement. The key elements of our Code of Ethics are:

• corporate transparency
• customer and partner confidence
• reputation of an open and reliable company providing high quality, affordable services.

Rostelecom has a zero tolerance approach to any manifestations of corruption, demonstrating commitment to high standards of business conduct and ethics in dealings with any and all stakeholders. Between 2014 and 2018, we developed a number of key documents covering corruption prevention (including the updated Code of Ethics, Anti-Corruption Policy, Regulations on the Conflict of Interest Management, Regulations on Giving and Receiving Gifts, Regulations on Charitable Donations and Assistance, etc.).

All Rostelecom’s new hires working at computer workstations undergo a mandatory distance training on the key elements of the Code of Ethics within 30 days upon employment. Employees in positions exposed to corruption risk undergo additional classroom and online training on preventing corruption.

Anti-Corruption Policy

The percentage of employees that Rostelecom’s key anti-corruption policies and procedures have been communicated to is 100%. New employees sign a document confirming that they have read a set of documents upon employment (including the corporate Code of Ethics, Anti-Corruption Policy, etc.), while relevant regulations are communicated to existing employees via the Company’s electronic document flow.

The Company’s anti-corruption efforts are carried out under the applicable Russian laws, including Federal Law No. 273-FZ On Countering Corruption dated 25 December 2008.

In 2018, the Company developed and approved its Corruption Risk Mitigation Programme for 2018 (the Compliance Programme), defining the activities to prevent corruption, and minimise and/or mitigate the consequences arising from corruption.

Conflict of interest management

In June 2018, Rostelecom launched an automated system to resolve conflicts of interest. Any Rostelecom employee with a conflict of interest, as well as employees in positions exposed to a higher corruption risk regularly complete electronic declarations. Using pre-determined criteria, the system automatically identifies employees who should submit the declarations and monitors timely completion of declarations by these employees. Links to complete the declarations are sent automatically, thus excluding the human factor from mandatory disclosures.

The Octopus automation software helps identify affiliations between service providers. To minimise corruption risks in procurement (as part of monitoring the performance of PJSC Rostelecom’s agreements), an automated cost control system is being developed and integrated into business processes related to telecommunications service set-up projects.

To foster business relations with counterparties supporting PJSC Rostelecom’s Anti-Corruption Policy and declaring zero tolerance for corruption, Rostelecom has in place its Code of Supplier Business Ethics and uses an anti-corruption clause allowing it to terminate a contract with a counterparty due to violations of the obligation to refrain from any actions prohibited by anti-corruption laws. The anti-corruption clause is included in Rostelecom’s every expenditure agreement worth over RUB 500,000.

In 2017–2018, to raise awareness of SMEs on the specifics of participation in procurement processes of major organisations, including the need to comply with anti-corruption laws and business ethics standards, PJSC Rostelecom and Joint Stock Company Russian Small and Medium Business Corporation (JSC RSMB Corporation) held 54 educational workshops for the Company’s counterparties and potential service providers in Russian regions. Saint Petersburg, Vladivostok, Yekaterinburg, Krasnodar, and other regional centres were among the major cities hosting our workshops.

The Anti-Corruption Policy came into force in 2014 and outlines basic principles and requirements for compliance with anti-corruption laws by all Rostelecom employees, top management, and members of the Management Board and the Audit Commission.

In 2018, 480 employees of the Company and 420 employees of Rostelecom subsidiaries were trained on anti-corruption issues (as per the requirements of anti-corruption laws) through distance or classroom learning.

The Company combines its anti-corruption efforts with cooperation with anti-corruption NGOs. Rostelecom has in place its Council for Business Transparency which comprises representatives of the Russian Ministry of Digital Development, Communications, and Mass Media, Chamber of Commerce and Industry, mass media, higher education institutions, and anti-corruption NGOs. In 2018, the Council held two meetings to review progress on anti-corruption measures, transparency and openness of the Company’s procurement processes, the statistics on reports in corporate feedback channels, etc.

Rostelecom is actively involved in the efforts to develop new and update existing anti-corruption laws. In 2018, amendments to the regulations introducing a list of measures to enhance the effectiveness of the national anti-corruption policy were drafted and submitted to the Russian Government.

Rostelecom joined the Anti-Corruption Charter of Russian Business in 2014. The Charter requires that the Company integrates anti-corruption programmes into its corporate policies and performs their monitoring and progress assessments; maintains robust financial control and makes public its anti-corruption measures; never seeks to gain undue advantages; makes bids transparently and competitively; cooperates with the government; helps justice and law-enforcement; and takes other measures.

The Company’s management is actively involved in promoting an ethos of zero tolerance for any forms and manifestations of corruption across all levels, role modelling the desired behaviours and setting the Tone from the Top. For example, Rostelecom’s Anti-Corruption Policy is prefaced by a personal letter from the Company’s President highlighting the importance of compliance with anti-corruption laws. In June 2017, the Company’s President Mikhail Oseevsky made an opening statement for the online broadcast of the corporate Compliance Day event, in which he underlined the top management’s commitment to zero tolerance for any manifestations of corruption and the importance of compliance with this principle for all Rostelecom employees. A video titled «Rostelecom against Corruption» has been posted on Rostelecom’s anti-corruption portal, featuring the Company’s top managers in a brief Q&A on the importance of anti-corruption and the ways to combat corruption they see as the most effective. The materials are available atwebsite.

In 2019, in line with the Company’s strategy of digital transformation, we will focus on automation of compliance processes, including the development of the Compliance Control automated system to resolve conflicts of interest, and handle employee and third party enquiries.

To enhance the Tone at the Top, Rostelecom plans to establish the Institute of Regional Compliance Representatives in its regions of its operation.

Human rights

PJSC Rostelecom protects and respects human rights by assuming relevant obligations, assessing the Company’s risks and impacts, engaging with stakeholders, and communicating with its employees and contractors. Human rights monitoring and reporting are high on the Company’s list of priorities.

Rostelecom promotes human rights in its business relations with all business partners and encourages them to protect and respect human rights. Suppliers of PJSC Rostelecom are expected to share our corporate ethos, and their activities must comply with the relevant applicable laws. Only those suppliers who comply with the law, have zero tolerance for corruption, respect human rights, and promote employee health and safety can become our long-term partners.

Rostelecom is committed to ensuring adherence to human rights across all our units. To this end, we promote information sharing on human rights issues within the Company, develop procedures and training, and monitor and assess progress. All our employees and suppliers are required to complete trainings and a series of dedicated courses on human rights. Rostelecom discloses its progress on human rights as an integral part of its dialogue with stakeholder groups.

No risks for incidents of forced or compulsory labour and no infringements on the rights of indigenous and small-numbered peoples were identified in 2018. PJSC Rostelecom conducts its business in full compliance with the labour law of the Russian Federation. The Company does not use child labour.

Remuneration is determined in line with the applicable regulations covering the minimum wage, standard work hours, and overtime. The Company’s employees are free from harassment and illegal discrimination regardless of their race, skin colour, religion, ethnicity, gender, age, marital or any other status protected by law. Rostelecom supports the promotion of cultural, gender, and ethnic diversity. Mutual trust and respect are the foundation of our corporate culture. We provide equal opportunities to employees across all gender and age groups and prevent discrimination in management decision-making.

Rostelecom does not limit its employees’ right to form non-governmental organisations representing their interests. We recognise the employees’ right to form, join, or not to join such organisations without fear of consequences or penalties. PJSC Rostelecom signs a collective bargaining agreement to make sure relationships with employees are based on the principles of social partnership and protection of their social and labour interests.

The corporate Code of Ethics sets out the employees’ right to engage in any political, educational, charitable, or community activities provided that these activities do not impact the performance of their immediate jobs and do not contradict or harm PJSC Rostelecom’s interests.

Employees can report violations of the Company’s Code of Ethics to the corporate Hotline at ethics@rostelecom.ru.

We guarantee that the personal details of such employees and the reported information will be used confidentially, exclusively for the purpose of a follow-up investigation, and only by people directly involved in the investigation. PJSC Rostelecom guarantees that no retaliation will be attempted against persons reporting such violations in good faith. The Company prohibits its staff from prosecuting or putting pressure on employees reporting alleged violations of the Code of Ethics or involved in relevant investigations.