Anti-corruption policy

Our approach

EVRAZ is committed to strict compliance with the Law of the Russian Federation #273 “On Preventing Corruption,” the UK Bribery Act, the US Foreign Corrupt Practices Act and other relevant local legal equivalents. EVRAZ has implemented internal policies on these matters to comply with both the letter and the spirit of these laws. The compliance team provides internal monitoring and control over areas generally perceived as holding risks of corruption at all EVRAZ assets. The compliance manager routinely reports to the senior vice president for business support and interregional relations and delivers regular updates on the status of anti-corruption efforts to the Audit Committee. Policies and regulations EVRAZ subsidiaries in the Russian Federation, Ukraine, Kazakhstan, the US and Canada enforce a Code of Conduct and Anti-corruption policy, which are the key documents defining norms of ethical and responsible behaviour of employees in all circumstances. All policies are available on the corporate intranet and employees are required to adhere to them by taking personal responsibility for compliant behaviour. Employees are encouraged to approach compliance managers whenever they have questions about expected course of actions in difficult situations or when they want to voice concerns about known policy violations.

Key developments
In 2016 All elements of EVRAZ’ compliance system have been implemented across its Russian and Ukrainian sites, which were considered priority targets for anti-corruption compliance efforts. In March 2016, the esteemed organization assessed emerging market multinationals and published their research paper “Transparency in Corporate Reporting”. The document mentioned the high results achieved by EVRAZ in building up its anti-corruption program. EVRAZ achieved a score of 85%, which compares favourably with the average of 74% for the technology sector or the average of 48% for all companies considered in the assessment. All business processes bearing high corruption risk are now duly covered by corresponding corporate regulations and policies, either updated or developed anew. The areas of concern include procurement of goods, works and services, government relations, archiving of tendering documentation, recruitment, sponsorship and charity payments, selling of goods, works and services. The effectiveness of these policies is closely monitored by the compliance and asset protection, internal audit and legal departments. All EVRAZ sites have Anti-Corruption Compliance units. They routinely run checks on candidates, tenders, clients and potential conflicts of interest; conduct investigations into possible non-compliance with policies; monitor charity payments and hospitality spending; and act on whistleblower allegations of possible fraud, bribery or corruption. Compliance Managers submit findings and any recommendations to local Managing Directors. Each month, the managers report all results to the Company’s Compliance Officer and specialists under the Senior Vice President for Business Support. Once a year, all Compliance Managers conduct comprehensive anti-corruption and fraud risk analyses in their respective areas. The findings are presented to local managers, who undertake corrective measures if necessary. The Company’s Compliance Officer then presents a consolidated analysis to the Audit Committee. Anti-corruption training is progressing steadily. Overall, the number of employees who have received training to date is close to 6,000.

Key documents

The Code of Conduct is the key document that all employees are requested to adhere to and act in full accordance with. Every new employee is trained on the Code of Conduct on their first day of work.

EVRAZ’ Anti-corruption policy sets and explains key principles that have been adopted at all assets to prevent corruption.

All aspects of EVRAZ’ sponsorship and charity efforts are regulated as necessary by this policy. Under it, the Group may consider supporting low-income or physically challenged individuals, and those suffering from conflicts or natural disasters. EVRAZ may choose to support certain projects in education, sport, health care, culture, and environment protection.

EVRAZ believes that business gifts and hospitality are accepted ways to demonstrate and further develop good relationships. At the same time, adequate consistent control over such expenses is very important and is among the key areas for anti-corruption compliance to watch. The policy defines rules and strict approval procedures to be followed when extending or receiving gifts and hospitality.
EVRAZ encourages employees to raise concerns to their line managers if they believe the company’s policies or cardinal principles are somehow violated. If employees, clients, or contractors feel unable to do so via other means and procedures, a confidential hotline is available 24/7.

In addition to the policies mentioned above, the company has applied a number of other documents regulating anti-corruption efforts. A brief summary is presented separately.