Compliance Service (Anti-Corruption)

• By phone:

  +7 (7172) 799 925

• Via the hotline:

  +7 777 880 44 04

• By email:

  compliance@igtipc.org

• At the office

  a whistleblowing box is available on the Company’s premises for the prompt receipt of written reports from employees, officials, counterparties, and other persons.

• 1.Receipt of the Report

  • Channels: hotline, email, whistleblowing box, written/oral submission, through a supervisor.
  • Reports are accepted 24/7 (except for the whistleblowing box — checked daily at 17:00).

  → Submitted to the Compliance Service.

• 2.Registration of the Report

  • The report is registered in the log within 1 working day.
  • The following are recorded: reference number, date, author (if available), subject, nature of the violation, and status.

  → Decision: accept or reject.

• 3. Initial Decision by the Compliance Service

  The report is rejected if:

  • the nature of the violation is not disclosed;
  • it does not fall within the scope of the Policy;
  • the submission has been sent to multiple authorities and is subject to review under the Administrative Procedure and Process Code (APPC).

  In this case, the applicant (if not anonymous) is sent a notification.

  Alternatively, the report is accepted for review.

• 4.Preliminary Review (up to 5 working days)

  Establishment of the factual circumstances.
  Determination of whether there are indications of a violation, damage, or constituent elements of an offense.
  The Compliance Service may request documents and information from structural divisions.

  If no indications are found:

  • the review is terminated;
  • the applicant is notified (if contact details are available);
  • explanations may be obtained from the subject concerned.

  If indications are found:

  → Initiation of an internal investigation.

• 5. Internal Investigation

  • Conducted in accordance with the Company’s internal act.
  • Collection of evidence, explanations, and documents.
  • Full confidentiality and protection of the applicant are ensured.

  → Upon completion, a report is prepared.

• 6. Results and Response Measures

  • Measures are taken depending on the identified violations.
  • Possible referral to law enforcement authorities (if a corruption-related offense is established).
    → The information is included in reporting.
• 7. Notification of the Applicant

  • Within 10 calendar days from the commencement of the internal investigation.
  • Notification on the status or final results is provided (within the limits of confidentiality).
  • An anonymous applicant is notified only through the channel indicated by them (if such option is предусмотрено / available).
• 8. Monitoring and Reporting

  • All reports are included in the Compliance Service’s periodic reporting.
  • Information is submitted to the Board of Directors.
  • In the event of material violations, the Chairman of the Management Board, the Chairman of the Board of Directors, and the authorized anti-corruption authority are informed immediately.
• 9. Record Retention

  • Reports and all related materials are retained for at least 5 years.
  • Access is granted only to members of the Board of Directors.

Regulatory Framework

Information on the implementation of recommendations based on the results of the internal corruption risk analysis

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