Activities of the LUKOIL Group are based on the corporate values allowing for doing business in accordance with high ethical standards, including strict compliance with laws, unconditional respect for human rights, zero tolerance towards any corruption and adherence to fair competition rules.
Ethical principles set forth in the Code of Business Conduct and Ethics of PJSC LUKOIL constitute a foundation of the Group's corporate culture and cover all aspects of business conduct. The Company extends the rules of ethical conduct to relations with its partners, vendors and contractors informing them of its corporate rules and strongly suggests them to familiarize themselves with its Code of Business Conduct and Ethics.
The Code of Business Conduct and Ethics contains rules that are consistent with the best international practice and standards of business ethics.
The main mechanism for monitoring compliance with the corporate ethics rules is the Business Ethics Commission established to review respective issues and violations of the provisions set forth in the Code of Business Conduct and Ethics. The Commission is chaired by the President of PJSC LUKOIL. In case of situations requiring attention of the Company management respective information is provided to the chairman of the Commission.
Concerned parties can contact the Business Ethics Commission via any available means of communication (by sending an e-mail to the dedicated address, firstname.lastname@example.org, available around the clock, or a written request to the Business Ethics Commission, or by phone). The appeals are accepted in all languages of the countries where the Group operates
The Company guarantees the confidentiality of any person who has reported a violation. In addition to the Commission, employees can also report violations of the Code or their rights to respective trade union bodies.
The Code of Business Conduct and Ethics is a corporate document and therefore all employees of LUKOIL Group entities, including foreign-based ones, must comply with the corporate ethics rules. General directors of respective entities are responsible for making sure that their personnel comply with the local regulations.
In case of proven violations of the local regulations by the employees of the Group entities, a variable part of remuneration (monthly bonus/annual bonus) may be reduced. The amount to be reduced depends on significance of the identified violation.
The Antitrust Policy of the Company is based upon the rule of law, fair competition, the personnel's awareness of the requirements of the current antitrust legislation and on their personal responsibility to comply with those requirements.
Employees must familiarize themselves with the provisions of the Antitrust Policy and the requirement to comply with it in their activities. The Work Group for interaction of LUKOIL Group entities with the Federal Antitrust Service and its territorial bodies on issues related to production and commercial activities is in charge of controlling the compliance with the Antitrust Policy and other local regulations aimed at preventing violations of antitrust laws.
LUKOIL Group is committed to the zero tolerance principle which means that no form of corruption can be tolerated in its operations, irrespective of the jurisdiction and local laws even if they allow certain forms of corruption (e.g. facilitation payments).
The Company is not engaged in corrupt practices nor does it promote them, including on the part of its business partners, and uses its best efforts to prevent such acts. The practice of paying compensations or using other incentives when dealing with public officials is absolutely unacceptable for the Company.
The Anticorruption Policy sets common principles, goals and objectives to combat corruption. The Policy also describes key actions to mitigate risks of corruption in the following situations:
gifts and hospitality expenses;
conflict of interest and sponsorship, interaction with business partners, participation in politics, interaction with competitors, public authorities, etc.
Employees must acknowledge in writing that they have read the Policy as part of the hiring process.
Based on the due diligence principle, the Company checks the trustworthiness of counterparties of LUKOIL Group entities. An information management system was implemented for counterparty due diligence which allows for assessing the level of risks related to Russian counterparties at the stage of the conclusion of contracts for goods, work and services as well as at the stage of their execution. The system allows for automating the due diligence process and reducing the impact of the human factor on the assessment of such risks.
A dedicated Hotline (email@example.com) was created which can be used by any person to report actual or alleged violations of anticorruption laws and/or provisions of the Policy as well as express his/her wish to assist in investigations.