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The System of Actions in TVEL JSC and its Structural Subdivisions to Combat Misconduct and Corruption


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The management and the workers of TVEL FC fully share the anti-corruption policy implemented by the government of the country. In order to create conditions for reduction of corruption and embezzlement, the enterprises of the Fuel Company adopted a local regulatory document “Concerning implementation of complex program for anti-corruption and anti-embezzlement in TVEL JSC and companies of the management system of the Fuel Company”. The document is based on the approved by ROSATOM “Anti-Corruption Plan 2016–2017 of the State Atomic Energy Corporation “Rosatom”.

Within the implementation of the Complex program, ROSATOM approved the “Plan for Anti-Corruption Actions Improvement in ROSATOM”.

Anti-corruption orders of TVEL Fuel Company:

  • Concerning anti-corruption plan of JSC “TVEL” for 2014–2015;
  • Concerning arrangement of annual insight into the regulatory anti-corruption acts;
  • Concerning approval of the reporting procedure on the fact of inducement to corruption offences, verification of this information and notification registration;
  • Concerning approval of the Provision on gifts, invitations and business hospitality of TVEL JSC;
  • Concerning approval of TVEL JSC Policy in economic security and assets protection;
  • Concerning determination in TVEL JSC of subdivisions for prevention of corruption and other offences.
  • In 2016 TVEL JSC introduced the orders concerning the anti-corruption actions:
  • Concerning the measures to comply with it.it.5.1.-5.3 of the "Procedure for prevention and settlement of competing interests in TVEL JSC";
  • Concerning approval of the Provision on the Ethics Board of TVEL JSC;
  • Concerning approval of the Procedure of registration and consideration of notices from the employees of TVEL JSC on possible conflicts of interest;
  • Concerning approval of the Anti-corruption plan 2016-2017 of TVEL JSC;
  • Concerning approval of the procedure for reporting on corruption offences by other employees of TVEL JSC, counterparties of the company and other persons, and the procedure for considering such reports.

In 2016 TVEL JSC introduced the orders concerning anti-corruption actions:

  • “Concerning approval of the Provision on the Ethics Board of TVEL JSC”;
  • ”Concerning approval of the Procedure of registration and consideration of notices from the employees of TVEL JSC on possible conflicts of interest”;
  • “Concerning approval of the procedure for reporting on corruption offences by other employees of TVEL JSC, counterparties of the Company and other persons, and the procedure for considering such reports”;
  • “Concerning enacting Unified industry-specific procedure for checking reports on corruption or other violations that are received by hotline and other channels”;
  • “Concerning procedure for provision of income certificates and propertyrelated obligation“

To arrange a system for prevention of illegal behavior the following was established in TVEL Fuel Company:

  • Security Unit (at the level of TVEL JSC), including department of economic security, commercial secrecy safety department and Group of information and analytical support;
  • Assets Protection Subdivisions (at the SC level).

Actual number of the employees of Assets Protection Subdivisions of TVEL FC as of December 31, 2016 amounted to 60 persons.

8-800-100-07-07, 0707@rosatom.ru — contacts of the corporate hotline of ROSATOM State Corporation for anti-corruption and antiembezzlement in nuclear sector. For details visit ROSATOM website http://www.rosatom.ru/partnership/theft/, and TVEL Fuel Company website http://tvel.ru/wps/wcm/ connect/tvel/tvelsite/about/theft/.

MAIN FIELDS OF STRUCTURAL SUBDIVISIONS’ ACTIVITY

  • Economic security and protection of assets of TVEL JSC and its subsidiaries in the course of production and financial economic activity;
  • Revealing, prevention and localization of threats (risks) to economic interests and business reputation of TVEL JSC and its subsidiaries;
  • Information-analytical support of the President of the Company and structural subdivisions of the Company in economic security;
  • Maintenance of commercial and business secrecy system in the Company and its subsidiaries;
  • Arrangement of personnel security of the Company and its SC;
  • Development and implementation of measures aimed at prevention of corrupt behavior.

System for combating unlawful behavior in TVEL FC

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Structural subdivisions of TVEL FC for prevention of unlawful behavior perform continuous monitoring of assets flow, analysis of factors and terms that contribute to external and internal threats (risks) to assets and economic interests of TVEL JSC and SC, implement measures for prevention, combating and neutralization of their negative consequences. In 2016 the analysis covered all subsidiaries of TVEL Fuel Company.

TVEL JSC implemented the Standard Industry-Specific Instructional Guidelines on Assessment of Corruption Risks in Organizations of ROSATOM. Accordingly, all subdivisions analyzed their businessprocesses, with specification of critical points and description of probable corruption offences. Based on the analysis the Company elaborated the cards of the corruption risks and developed measures aimed at risks mitigation.

All employees of TVEL Fuel Company must study provisions and regulations on anti-corruption and anti-embezzlement. This information is communicated to 100% of employees. The Fuel Company holds activities aimed at employees training in the rules of business ethics, anti-corruption and anti-embezzlement. In addition, the external providers hold special briefings for employees of the relevant divisions on actual issues in anticorruption policy.

Besides, TVEL Fuel Company has its own industry-specific program on antiembezzlement and anti-fraud; for prompt decision-making the hotline was opened within the framework of this program. The program provides for material remuneration and protection of workers participating in the Program.

All suppliers and contractors are informed on anti-corruption policy and measures through procurement documents and contract provisions.


MAIN RESULTS 2016

474 inspections (476 in 2014) were arranged and performed to prevent damage and loss of assets

More than 30 appeals to law enforcement agencies, resulting in initiation of more than 20 criminal cases.

Disciplinary actions against 125 employees, seven of whom were dismissed.

90 inspections were carried out with regard to information on irregularities and violations received via specialized communication channels hotline, in 29 cases information was proved (in 2015 there were proved 48 cases of violation out of 118 checked).

The amount of prevented and reimbursed damage resulted from measures for economic safety and assets protection amounted to RUB 941 million.

There are no completed legal actions against the organization or its employees in connection with corruption.

Anti-corruption performance results

Indicator 2014 2015 2016 2016/2015
Number of inspections aimed to prevent damage and loss of assets

476

583

474

-19%

Number of materials submitted to law enforcement agencies

28

75

34

-55%

   instituted criminal proceedings

18

27

22

-18%

Disciplinary action against employees

130

146

125

-14%

   dismissed

26

22

7

-68%

   including along with submission of materials to law enforcement agencies

Number of inspections made to check information concerning abuses and violations received via specialized communication channels hotline

101

118

87

-26%

   confirmed

18

48

29

-40%

The amount of prevented and reimbursed damage resulted from measures for economic safety and assets protection, RUB mln

397

689

941

37%

ANTI-CORRUPTION PLAN 2016–2017 OF TVEL JSC

Main anti-corruption objectives are the following:

  • formation and improvement of legal and organizational basis of anticorruption of TVEL JSC in accordance with the requirement of the time;
  • execution of legal acts and managerial decisions in anti-corruption sphere aimed to create conditions reducing the possibility of corrupt conduct and providing the decrease of the corruption level;
  • intensified anti-corruption education of the employees of the Company;
  • ensuring the compliance by the employees of the Company with anti-corruption codes, including the requirements of the Art.13.3 of the Federal Law d/d December 25, 2008 No.273-FZ “Against corruption”, providing commitments of organizations to prevent corruption, and the Art.19.28 of the Code of Administrative Offences of the Russian Federation, providing for liability for illegal remuneration on behalf of the legal entity;
  • improving efficiency of awarenessraising and educational actions aimed to create the atmosphere of non-tolerance of corruption in the Company;
  • enhanced activity of subdivisions for assets protection aimed at prevention of corruption and other violations of law.

To achieve the set objectives, the Plan provides for the following actions:

  • improving efficiency of awarenessraising actions aimed to create the atmosphere of non-tolerance of corruption in the Fuel Company;
  • timely identification, prevention and settlement of conflicts of interest in activity of the Company’s employees;
  • prevention of different criminal offences;
  • prevention of property damage.

In accordance with the Policy of ROSATOM and TVEL JSC the system of physical protection and security of all enterprises is being continuously improved, the issues related to counterterrorism security of the facilities of the Fuel Company are being regularly addressed.

1.
Москва
АО «ТВЭЛ», АО «ВНИИНМ»,
АО «МЗП», АО «ЦПТИ»

2.

Московская область

АО «МСЗ» (электросталь)

3.

Санкт-Петербург

Филиал ООО «НПО «Ценротех»

4.

Владимирская область

АО «ВПО «Точмаш» (Владимир),
ПАО «КМЗ» (Ковров)

5.

Удмуртская республика

АО ЧМЗ (Глазов)

6.

Свердловская область

АО «УЭХК»,
ООО «НПО «Центротех» (Новоуральск)

7.

Новосибирская область

ПАО «НЗХК» (Новосибирск)

8.

Красноярский край

АО «ПО «ЭХЗ» (Зеленогорск)

9.

Томская область

АО «СХК» (Северск)

10.

Иркутская область

АО «АЭХК» (Ангарск)