Management approach
GRI 3‑3, 205‑3
Russian Railways’ Code of Business Ethics serves as the main document establishing corporate requirements and rules of official conduct, including in the field of preventing and combating corruption. It enshrines key behavioural standards that are mandatory for members of the Board of Directors and every Company employee. The Code reflects the mission, values and principles of Russian Railways.
Anti-corruption management is integrated into our sustainable development system and is implemented through the requirements of the Anti-Corruption Policy, aimed at preventing, detecting and combating corruption offences, as well as minimising associated risks. The Policy ensures compliance with Russian laws and contributes to establishing a culture of zero tolerance for corruption at all management levels.
Russian Railways’ anti‑corruption policy outlines the following priorities:
- creating a unified approach that rejects any manifestations of corruption among Company employees, Board of Directors members, and stakeholders;
- communicating the importance of publicly declaring zero tolerance for corruption and bribery in business;
- maintaining strict compliance of Russian Railways’ activities with the Russian anti‑corruption legislation.
Russian Railways’ anti‑corruption policy is underpinned by the following principles:
- strict compliance with Russian laws, international agreements, and generally accepted anti‑corruption standards;
- zero tolerance for corruption in all its manifestations regardless of the nature and line of activity;
- monitoring and regular assessment of corruption risks;
- controlling the effectiveness of anti‑corruption procedures;
- due caution in activities and managerial decision‑making;
- systematic training of employees in anti‑corruption fundamentals.
Our anti‑corruption system rests on a comprehensive approach and includes an established code of behavioural standards covering duties, restrictions, and prohibitions. Compliance with these requirements is embedded in employment contracts and is mandatory for all employees, including managers at all levels.
Improving our anti‑corruption policy
As part of strengthening anti‑corruption activities, we implemented measures in 2024 that enhance transparency and enable prompt response to potential threats:
- we updated our Anti‑Corruption Policy, particularly aligning the concept of “abuse of authority” with the note to Article 285 of the Russian Criminal Code;
- we established the obligation to send all notifications without exception about inducing Russian Railways’ employees to commit corruption offences to law enforcement agencies.
Beyond personal responsibility, administrative sanctions can be applied to the Company itself for non‑compliance with established restrictions when employing former state and municipal employees.
According to legislation, when concluding an employment or civil law contract with a former government or municipal official, the organisation must send a notification to their last place of service within ten calendar days. Non‑compliance with this requirement may result in administrative liability.
Russian Railways takes necessary measures to prevent such violations:
- letters with clarifications are sent to heads of units;
- visual instructions are distributed, with an algorithm of actions when employing former government officials;
- a respective notification form was added to the Human Resource UCAS, with the system also displaying a pop-up window to remind the user to send the notification to the previous employer of the former government or municipal official.
These measures resulted in the complete absence of cases bringing the Company to administrative liability in 2024.