The Company informs that in accordance with the UN Convention against Corruption dated October 31, 2003, ratified by the Russian Federation in 2006 (most of the provisions of the Convention were ratified) and the Federal Law of the Russian Federation “On Combating Corruption” adopted in pursuance thereof, as well as in connection with the ratification of the Convention Council of Europe “On Criminal Liability for Corruption”, in ABAKAN AIR LLC, being an international public company, has implemented regulatory documents aimed at increasing transparency and combating corruption, including the “Policy in the Field of Combating Involvement in Corrupt Activities”. Based on the said corporate regulatory documents, a list of positions has been approved for which it is mandatory to provide the Company with information on income, property and property-related obligations, both in relation to oneself, and in relation to one’s spouses and minor children. This list includes the positions of the CEO and Chief Accountant of the Company, heads of structural divisions and their deputies, heads of departments and their deputies.
In addition, ABAKAN AIR LLC adopted a number of other regulations aimed at eliminating legal and reputation risks. In particular, the Company has the “Code of Business and Corporate Ethics of ABAKAN AIR LLC”, the norms of which are obligatory for all executives and employees.
The Company management regularly assesses the risks of corruption inherent in the industries and jurisdictions where business activity is carried out, and also reviews the identified facts of conflict of interest, for which appropriate response measures are taken, up to and including dismissal.
ABAKAN AIR LLC has applied a set of measures to use transparent mechanisms and implement effective procurement procedures. The Company also regularly interacts and exchanges information with state regulatory authorities, in particular, with the Ministry of Finance of the Russian Federation, the Federal Financial Monitoring Service, the Accounts Chamber of the Russian Federation, and the Central Bank of the Russian Federation.
Definition of Corruption
In accordance with Article 1 of the Federal Law of December 25, 2008 No. 273-FZ “On Combating Corruption”, the following actions are recognized as corruption:
a) abuse of office, giving a bribe, accepting a bribe, abuse of authority, commercial bribery or other illegal use by an individual of his or her official position contrary to the legitimate interests of Company and the state in order to obtain benefits in the form of money, valuables, other property or services concerning property, other property rights for themselves or for third parties, or the illegal provision of such benefits to the specified person by other individuals;
b) commission of acts specified in clause (a) of this paragraph, on behalf of or in the interests of a legal entity.
ABAKAN AIR LLC is a public company, therefore the activities of the Company and the actions of its employees in any country of the world must comply, inter alia, with the requirements of the anti-corruption legislation of the Russian Federation, the UK Bribery Act 2010, the US FCPA (Foreign Corrupt Practices Act 1977) and take into account the requirements of other laws and regulations of foreign countries where the Company operates or intends to operate.
The Company’s “Policy in the Field of Combating Involvement in Corrupt Activities” provides the following definition:
Corrupt actions means offering, giving, promising, soliciting or receiving bribes, mediating in bribery, making payments to simplify administrative, bureaucratic and other formalities in any form, including in the form of money, other valuables, services or providing/receiving unreasonable material or non-material benefit from any individuals/entities or to any individuals/entities, including representatives of the state, public groups, private companies and politicians.