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THE MINISTRY OF LABOUR OF THE RUSSIAN FEDERATION ISSUED GUIDANCE ON ANTI-CORRUPTION COMPLIANCE

The Ministry of Labour of the Russian Federation issued three new sets of anti-corruption guidelines for companies:

  1. “Measures for Preventing Corruption at Organizations”;
  2. “Recommendations on the Procedure for Assessing Corruption Risks at Organizations”;
  3.  “Memorandum on Establishing the Duties of Employees for Preventing Corruption, Employee Liability, and Incentive Programs”.
The recommendations should help companies properly fulfill their duties to prevent corruption in accordance with article 13.3 of Federal Law No. 273-ФЗ, dated 25 December 2008, “On Combating Corruption”.

The recommendations provide for measures aimed at minimizing the corruption risks of companies, including those related to:
  • development of anti-corruption policies and company standards;
  • establishing standards and codes of conduct for the employees;
  • providing conflict of interest regulation;
  • building an effective system for obtaining information on corruption offenses;
  • providing an assessment of the integrity of counterparties;
  • organization of internal control and proper accounting;
  • and others.

The Ministry of Labour paid special attention to the algorithm for assessing corruption risks. The specific measures that organizations need to take based on their risk profile will be based on this algorithm.

Earlier the Ministry of Labour has already developed guidelines in the field of anti-corruption in 2013. Formally new Recommendations do not cancel adopted earlier. However, it should be noted that the new Recommendations summarize the current Russian and foreign law enforcement practices and are more advanced than the previous one.