1. General provisions
1.1. This Regulation establishes the basic principles of the anti-corruption policy and control over their observance in the NEKKO LLC organization (hereinafter referred to as the Organization).
1.2. This Regulation has been developed in accordance with the Constitution of the Russian Federation, international legal acts aimed at combating corruption, the current legislation of the Russian Federation in the field of combating corruption, the Charter of the Organization.
1.3. This Regulation is obligatory for observance by all employees of the Organization.
1.4. This Regulation comes into force from the moment it is approved by the order of the head of the Organization and is valid until the approval of the new Regulation.
All changes and additions to these Regulations must be approved by order of the head of the Organization.
2. Goals and objectives of the anti-corruption policy of the Organization
2.1. The main goal of the anti-corruption policy of the Organization is to eliminate the causes of development and formation of the conditions for the existence of corruption in the Organization.
2.2. Objectives of the anti-corruption policy:
- development and implementation of measures to prevent, suppress and minimize the consequences of corruption in the Organization;
- detection and prevention of involvement of employees of the Organization in corrupt activities;
- elimination of external factors that could involve the Organization in corrupt activities;
- creation of a system of compensation for harm caused by corrupt actions of the Organization;
- development of incentives for employees who are not prone to corrupt practices and are not convicted of corrupt activities.
3. Implementation of the anti-corruption policy in the Organization
3.1. To perform the tasks outlined in Sec. 2 of this Regulation, an anti-corruption commission is created in the Organization.
3.2. The anti-corruption commission is created in the amount of 3 people. It consists of (indicate the positions of employees who may be part of the commission):
- CEO;
- Chief Accountant;
- Financial director.
3.3. Members of the anti-corruption commission are appointed by the head of the Organization and change every year.
3.4. The work of the commission is headed by the chairman of the commission, appointed by the head of the Organization.
3.5. The activities of the Commission are aimed at identifying facts of violation of anti-corruption legislation or preventing actions of the Organization’s employees that could lead to corrupt practices.
3.6. To perform the above tasks, the Commission has the right to conduct various checks, make inquiries to various divisions of the Organization, and get acquainted with the personal files of the Organization’s employees.
3.7. Any employee of the Organization has the right to apply to the commission, including anonymously, with a statement about a violation of the anti-corruption policy that has become known to him or about a possible violation of the anti-corruption policy.
3.8. If a fact of violation of anti-corruption legislation is revealed, the commission investigates this fact, identifies the reasons for the commission of a corrupt act, determines the consequences and reports to the head of the Organization.
3.9. The head of the Organization, on the basis of the report of the commission, takes appropriate measures to bring the perpetrators to justice and eliminate the consequences of the harm caused by corruption.
3.10. If the commission reveals circumstances that may provoke the commission of corrupt acts by an employee of the Organization, the commission, together with the trade union body, conduct conversations with the specified employee, find out the reasons that led to the creation of such a situation, provide the head of the Organization with recommendations on how to take measures to prevent such situations in relation to this employees and other employees in general, identify employees who fall into the risk group for similar reasons.
3.11. If the commission becomes aware of the fact of violation of the anti-corruption policy by third parties in relation to the Organization, the commission is obliged to immediately report this to the head of the Organization in order to involve the relevant law enforcement agencies and prevent harm to the Organization.