2014 Annual report

Anti-corruption Policy

Anti-corruption policy of JSC IDGC of the North-West (hereinafter, the Policy) defines the objectives of the Company’s involvement in combating corrupt practices and compliance with applicable anti-corruption laws of the Russian Federation, as well as applicable anti-corruption legislation in the areas of presence of interests of the Company and its subsidiaries.

The policy defines objectives, ways of solutions and underlying principles of combating by IDGC of the North-West the corrupt activities, as well as measures to minimize the risk of engaging in the corrupt activities.

The purpose of anti-corruption policy is the development and implementation of versatile and consistent measures to prevent, eliminate (minimize) the causes and conditions that give rise to corruption, the formation of anti-corruption awareness characterized by intolerance to corruption from managerial and control bodies, the Company’s employees, members of the public, shareholders, the investment community, counterparties and other Company stakeholders.

The objectives of the anti-corruption policy are:

Basic principles to counter the involvement in corruption practices:

Anti-corruption monitoring

Anti-corruption monitoring includes monitoring of anti-corruption measures and activities undertaken within the anti-corruption policy of the Company, as well as revealed facts of corruption and ways to eliminate them.

The main areas of anti-corruption monitoring are:

Implementation of anti-corruption measures

In 2014, members of the security departments organized and conducted 139 audits of financial and business activity; prevented damage amounted to RUB 13.3 million.

Under the revealed facts, 235 employees of the Company were brought to justice; 16 were fired, 62 brought to administrative responsibility, 190 — deprived of bonuses.

In 2014, security departments continued to check compliance with the order of tender procedures, verification of potential participants and winners, revealing facts of affiliation, lobbying and conflicts of interest. During the reporting period, 667 negative opinions were sent to the bid evaluation commissions.

3,639 potential contractors were checked during the tender procedures in order to identify affiliation, resulted in 99 negative opinions.

In 2014, 3,996 employees and their family members were checked for potential affiliation with the Company’s counterparties; signs of affiliation were revealed in respect of 7 employees or their families.

788 candidates for vacant positions were tested in order to identify personal or indirect affiliation with the counterparties; 17 negative conclusions were issued.

5,089 declaration of conflict of interest were checked. Security employees of the branches found 47 violations in filling the declarations and 6 conflicts of interest.