RUSSIA

Egorov Puginsky Afanasiev & Partners

"The best choice for solving multilevel issues with a marked Russian character"

Chambers Global

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Moldova Moldova Moldova Moldova Moldova

40/4 Bol. Ordynka

Moscow, 119017

Tel: +7 (495) 935-8010

Fax: +7 (495) 935-8011

22-24 Nevsky pr.,Suite 132

St.Petersburg, 191186

Tel: +7 (812) 322-9681

Fax: +7 (812) 322-9682

3 Gough Square

London EC4A 3DE

Tel: +44 (0) 20 7822-7060

Fax: +44 (0) 22 7353-5905

www.epam.ru

6. Recommendations on Companies’ Compliance Policies

We recommend:

  • inclusion of the procedure envisaging that at the time a former state or municipal civil servant is employed, it is verified whether a permission for such employment should be sought (in case it creates a conflict of interest) and that, if required, such permission is obtained;
  • procedures ,aimed to verify before the event whether any benefit provided for such servant in relation to the event may be prohibited by the Russian legislation, and that if such benefit is permitted it is appropriately documented, are put in place for events involving state civil servants;
  • introduce internal anticorruption standards taking into account the provisions of Russian anticorruption legislation
  • the price of gifts to state civil servants shall not exceed the limits provided by law;
  • gratuitous provision of paid-for services may be treated as giving a bribe;
  • ensure systematic education of the employees on anticorruption legislation provisions, including the one that any person may be held responsible for some violations of anticorruption laws such as giving a bribe.;
  • advise the employees of the obligations imposed on state civil servants. For example, of the obligation of the state and municipal civil servants to notify prosecutor’s office and other state authorities of all instances when such servants are approached by any persons for the purpose of encouraging the servant to commit a corruption-related offence.