Gazprom-AR2014

Corporate Governance
125
Corporate Ethics and Anti-corruption Practices
OAO Gazprom has the Code of Corporate Ethics in place, developed with due account for the
best Russian and international corporate governance practices. The Code sets forth
OAO Gazprom’s underlying corporate values and critical business conduct rules that exclude any
conflict of interest situations and corruption.
The Code’s provisions are mandatory for OAO Gazprom’s employees (including all members
of the Management Committee and the Board of Directors who are OAO Gazprom’s employees)
and the Company-controlled corporate entities. For employees of corporate entities with
OAO Gazprom’s shareholdings who are not controlled, and employees of OAO Gazprom’s counterparties
the provisions are recommendatory only.
Information on conflicts of interest of members of OAO Gazprom’s Management Committee and Board
of Directors (including those related to their service on management bodies of the Company’s competitors)
In 2014, all members of the Management Committee and the Board of Directors, who are OAO Gazprom’s employees,
signed up to the Code of Corporate Ethics of OAO Gazprom. The Code contains certain restrictions, including
restrictions related to OAO Gazprom employee’s service in competing companies. The Corporate Ethics Commission
of OAO Gazprom received no reports of any conflict of interest of members of the Management Committee and/or
the Board of Directors, who are OAO Gazprom’s employees, including conflict of interest related to their service on
management bodies of OAO Gazprom’s competitors.
The permanent Corporate Ethics Commission of OAO Gazprom set up by OAO Gazprom’s
Order No. 59 dated 11 February 2014 is authorised to supervise compliance with the Code’s
requirements and provisions.
In the reporting year, the Commission arranged for the Company’s management to sign up
to the Code; arrangements were made to implement its certain sections with respect to relatives
working together, interaction with competitors and counterparties, and the Commission’s procedures
for resolving conflict of interest situations of sole executive bodies of entities controlled
by the Company. At its meetings, the Commission discussed the reported cases.
Pursuant to the laws of the Russian Federation and OAO Gazprom’s regulations,
OAO Gazprom’s Corporate Protection Service and corporate protection units of the subsidiaries
work to prevent and reveal cases of corrupt practices in Gazprom Group. The work relies on an
ongoing interaction with the business units authorised with internal control, corporate costs management,
asset management and corporate relations, and Russian law-enforcement agencies.
Since 2014, OAO Gazprom has operated a Hotline to report incidents of perceived fraud, corruption
and theft in Gazprom Group. All reports are closely investigated and examined. No corrupt
practices were revealed in the situations reported through the Hotline in the reporting year.
OAO Gazprom Annual Report 2014