Anti-corruption, information security
Anti-Corruption Enforcement
The provisions of the Company’s Anti-Corruption Policy apply to all Company’s employees regardless of their position and official duties, and both Company’s counterparties and other persons if there are obligations between them and JSC “NIIneftepromchim” regarding compliance with the provisions of the anti-corruption clause.
In accordance with Article 1 of Federal Law dd 25.12.2008 N 273-FZ “On combating Corruption”, corruption is:
(a) abuse of office, giving a bribe, taking a bribe, abuse of authority, commercial bribery or any other illegal use by a natural person’s of his/her official position contrary to the lawful interests of society and the State for the purpose of obtaining a benefit in the form of money, valuables, other property or services of a pecuniary nature, other property rights for oneself or for third parties or the unlawful provision of such benefits to the said person by other natural persons;
(b) the commission of the acts referred to in subparagraph (a) of this paragraph on behalf or in the interests of a legal entity.
The Company has adopted a number of other regulations aimed at legal and reputational risk mitigation. F.ex., provisions of “Corporate ethics code”, adopted by the Company, are mandatory for all managers and employees.
Information security and privacy policy arrangements
The Company sticks to the Information Security Policy in order to protect information from possible material, physical, moral or other damage as the result of accidental or intentional impact on data, data carriers, data processing and transmitting and to ensure the efficient operation of the information-computer complex when exercising an activity specified by the Company’s Charter.
Employees of JSC “NIIneftepromchim” are obliged to follow the procedure of confidential documents, key information carriers and other protected data handling, comply with the requirements of the Company’s Policy and other internal documents on information security issues.
The Company has adopted the Insider information policy to settle matters concerning to establishment, modification and termination of the procedure for access to the Company’s insider information, rules for protecting its confidentiality and monitoring compliance with the requirements of the legislation on insider information in order to ensure fair pricing of financial instruments of JSC “NIIneftepromchim”, alignment of investors as to terms and scope of data received, enforcement of investor trust and preventing abuse in the form of misuse of insider information and (or) market manipulation.