The Group adopts a systematic approach to identifying, evaluating and managing corruption-related risk. At the end of each year, compliance managers carry out a comprehensive analysis of corruption risks across all the Group’s assets and business processes.

The Group takes a targeted approach and focuses on assessing existing controls and procedures in areas and business processes that are particularly exposed to risks of corruption. These areas typically include procurement, payments, sales, charity and sponsorship, business gifts and hospitality, interaction with government authorities, the vetting of business partners and contract approvals.

The Group’s Board of Directors and management pay special attention to promoting ethical behaviour and to preventing fraud, corruption and bribery at all organisational levels. The Audit Committee plays an important role in overseeing the overall efficiency of the Group’s anti-corruption system, and it reviews compliance controls, receives updates on ongoing compliance investigations and monitors issues related to corruption risks.

In order to boost the efficiency of anti-corruption and anti-bribery efforts and to ensure the timely oversight of these matters, the Group has appointed a corporate compliance manager and local compliance managers at each material subsidiary. The responsibilities of compliance managers include monitoring employee compliance with internal documents, investigating reported cases of misconduct and unethical behaviour and monitoring charity payments and hospitality spending. As part of their duties, compliance managers also vet potential and existing business partners and are involved in monitoring tender procedures, which are typically associated with higher risks of corruption.

All reports regarding potential cases of corruption, bribery and misconduct are scrutinised by compliance managers. The results of investigations and recommendations are presented to the asset’s senior management, the Group compliance manager and to the Senior Vice President for business support.

Raising awareness about ethical business conduct

An important component of the Group’s efforts to prevent corruption, fraud and bribery is consistently informing business partners and educating its employees about the principles of ethical business conduct and EVRAZ’s anti-corruption policies and procedures.

The Group takes a proactive approach to updating our employees about the standards of corporate behaviour and the consequences of engaging in bribery and corruption. Since 2015, EVRAZ has been providing ethical business conduct training for management, specialists and administrative staff.

The Group understands that informing business partners about the principles of fair business conduct is equally important. EVRAZ takes all necessary steps to prevent misconduct, bribery and corruption among our suppliers and contractors by requiring them to familiarise themselves with relevant corporate documents, informing them about the Group’s policy of zero tolerance towards corruption and inserting anti-corruption provisions into all contracts.

See more in the “Ethics and business conduct” section of the Sustainability Report 2018.