1.3. Values, Standards, and Norms of Behaviour

The key documents setting values, principles, standards, and norms of behaviour at PJSC Gazprom are the Corporate Governance Code of PJSC GazpromApproved by the resolution of the annual General Shareholders Meeting of PJSC Gazprom dated June 30, 2017, Minutes No. 1, the Code of Corporate Ethics of PJSC GazpromApproved by resolution of the Board of Directors of OJSC Gazprom No. 2309 dated February 25, 2014 as amended by resolution of the PJSC Gazprom Board of Directors No. 2795 dated September 1, 2016, resolution of the PJSC Gazprom Board of Directors No. 3172 dated October 26, 2018, and resolution of the PJSC Gazprom Board of Directors No. 3307 dated August 20, 2019, and the Anti-Corruption Policy of PJSC GazpromApproved by resolution of the PJSC Gazprom Board of Directors No. 2846 dated November 15, 2016.

The Corporate Governance Code of PJSC Gazprom is updated if and when necessary, including to reflect relevant changes in the applicable legislation. In 2019, no changes were introduced into the Corporate Governance Code.

In 2019, the Code of Corporate Ethics was amended to apply to members of PJSC Gazprom Board of Directors and include a special provision designed to identify and prevent conflicts of interest among the members of PJSC Gazprom Board of Directors. Efforts were made to extend ethics requirements to the members of boards of directors at the entities controlled by PJSC Gazprom. Most of the Company’s subsidiaries used the Code of Corporate Ethics as a basis to develop and approve similar by-laws.

Starting from 2019, upon mutual agreement of the relevant parties, the contracts concluded by PJSC Gazprom include a clause requiring that counterparties of PJSC Gazprom comply with the Company’s Code of Corporate Ethics.

Advice on ethical behaviour (including queries addressed to the Corporate Ethics Commission) can be sought using a variety of communication channels: by phone (Hot Line number +7 495 719-11-71), by e-mail to ethics.comission@adm.gazprom.ru, or by making a request directly to the Chairman of the PJSC Gazprom Corporate Ethics Commission.

In case of a conflict of interest, employees can contact their immediate supervisors. If such supervisor fails to take measures to resolve the conflict or the measures taken are insufficient, employees are to inform the Commission thereof. In 2019, the Commission held seven meetings and reviewed 18 items, including those related to queries submitted by the employees of PJSC Gazprom and its subsidiaries.

The key corporate values of Gazprom are professionalism, initiative, willingness to engage in a dialogue, and mutual respect. These corporate values build not only on benevolence, promotion of cooperation and nurturing of a team spirit when addressing ongoing tasks, but also on the unconditional respect for human rights.

In the sphere of human rights, Gazprom shares the global vision of fundamental values and fully complies with the applicable Russian and international laws. The Company is primarily guided by the principles set out in the Constitution of the Russian Federation, the United Nations’ Universal Declaration of Human Rights, and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

Respect of human rights is an essential element of the Gazprom Group’s social obligations and an important block in building constructive relationships with the Company’s stakeholders. The key focus areas are:

• workplace rights;
• rights of local communities, including indigenous rights; 
• right to a safe environment;
• right to personal safety, with on-site and access authorization procedures taking into account the constitutional rights and freedoms of a person and citizen and the rights and legitimate interests of individuals and legal entities.

The Gazprom Group’s commitment to the respect of human rights, including the rights in the sphere of employment and labour, as well as the rights to health protection, education, favourable environment, traditional way of life, and preservation of native habitat, as well as the intention to preclude any forms of discrimination or forced labour have found their reflection in the following by-laws of the Company: 

• the Code of Corporate Ethics of PJSC Gazprom; 
• the HR Management Policy of PJSC Gazprom, its Subsidiaries and EntitiesApproved by instruction of OJSC Gazprom No. 49 dated November 7, 2006 and the General Collective Agreement of PJSC Gazprom and its subsidiaries;
• the Process Safety Management System Development Strategy of PJSC Gazprom until 2021Approved by order of PJSC Gazprom No. 432 dated June 22, 2017 (as worded in order of PJSC Gazprom No. 21 dated January 20, 2020) and the Occupational, Industrial, Fire and Road Safety Policy of PJSC GazpromApproved by order of PJSC Gazprom No. 416 dated September 17, 2019;
• the Environmental Policy of PJSC GazpromApproved by resolution of the Management Committee of OJSC Gazprom No. 21 dated May 25, 2015;
• the Regional Policy Concept of OJSC GazpromApproved by resolution of the Management Committee of OJSC Gazprom No. 32 dated May 22, 2003;
• Order No. 602 of PJSC Gazprom “On Approval of Instructions for On-Site and Access Authorization Procedures” dated December 28, 2019.

The Company’s commitment to the respect of human rights is further confirmed by its focus on engaging the partners and counterparties abiding by the applicable legislation and the corporate and business ethics rules adopted by the Gazprom Group.

Apart from complying with the law, the suppliers and contractors operating at the Gazprom Group’s facilities in Russia must also conform themselves to the Company’s corporate standards in the sphere of industrial safety.

There is no special procedure in place to assess the degree to which the Gazprom Group entities and their suppliers and contractors respect human rights.

Agreements (including those on partnership with the governments of Russian constituent entities) and contracts signed by PJSC Gazprom do not include human rights clauses or undergo human rights screening.

The Gazprom Group ensures that its employees have sufficient knowledge with regard to various aspects related to the respect of human rights. In 2019, the staff took training in human rights with a focus on, among other things, application of the labour and civil law, implementation of social policies, and fine-tuning of the industrial and occupational safety system. Distance learning courses in corporate ethics were also organized for the employees of PJSC Gazprom. There are no dedicated training programs devoted to human rights protection and relevant policies or procedures at the Gazprom Group.

However, human rights issues are included in mandatory briefings that cover 100% of the Group’s security personnel.

The Anti-Corruption Policy of PJSC Gazprom is the key document underpinning the Company’s efforts to prevent and fight corruption. It is designed to introduce a unified approach to the Company’s mission of preventing and combating corruption for the benefit of civil society, shareholders and employees. The Anti-Corruption Policy of PJSC Gazprom sets out, among other things, the goals, competencies and responsibilities of governance bodies, and a set of measures developed to prevent and combat corruption.

Gazprom conducts monitoring of operations with the greatest exposure to corruption risks, with procurement and contract execution defined as the most vulnerable areas. To identify a potential conflict of interest in procurement activities, contracts concluded with the Company’s counterparties require that the counterparties disclose their ultimate beneficiaries.

The Company offers professional development educational programs on how to prevent and combat corruption, which are designed for newly appointed executives and specialists of PJSC Gazprom Administration or other professionals directly involved in the anti-corruption activities. In 2019, 89 employees received training under these programs. Moreover, Gazprom Corporate Institute put in place offline and online anti-corruption training programs for the employees of PJSC Gazprom’s branches, subsidiaries and entities. In 2019, the total number of the Gazprom Group employees who took training in combating corruption reached 1,144.

Fraud, corruption and embezzlement can be reported round-the-clock via the Gazprom Group’s Hot Line. The information received via the Hot Line, including anonymous messages, is analysed to identify actual or potential cases of corruption within the Gazprom Group.

In 2019, the Hot Line processed over 900 reports, with only 81 of them directly related to potential breaches of the legislation of the Russian Federation in the Gazprom Group. The most frequently encountered topics include potential procurement violations, third-party fraud, and complaints related to the sales of gas to end consumers. All incoming reports have been duly processed.

In 2020, the Company intends to continue enhancing corporate ethics requirements in its controlled entities, including by extending the scope of restrictions to cover the members of boards of directors, as well as by introducing regular employee training with knowledge assessments in the form of post-training tests. The number of employees who upgrade their skills in anti-corruption is also set to increase. The work will continue to integrate human rights principles into the Company’s corporate governance system. The efforts in this direction have a long-term priority with a significant potential for further development.