NLMK do not tolerate any form of corruption or fraud either within the company or in our relations with third parties. In accordance with the
Anticorruption Policy, employees and any other persons acting on behalf of the company are prohibited from engaging in corrupt practices.
NLMK Group is continuously improving its anticorruption compliance system which includes the following elements:
Organizational elements
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risk assessment
-
organizational set-up
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bylaws/internal regulatory documents
Developing a compliance culture
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training programme
-
internal and external communication programme
-
incentive programme for contributing to the development of the company's compliance culture
Monitoring, auditing and reporting
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internal auditing programme
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reporting and self-assessment of performance
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external performance assessment
Tools
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declaring a conflict of interest
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whistleblowing mechanisms
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contractor qualification and auditing procedures
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registering business gifts and event invitations
Anticorruption Compliance System
Organizational elements
-
risk assessment
-
organizational set-up
-
bylaws/internal regulatory documents
Developing a compliance culture
-
training programme
-
internal and external communication programme
-
incentive programme for contributing to the development of the company's compliance culture
Monitoring, auditing and reporting
-
internal auditing programme
-
reporting and self-assessment of performance
-
external performance assessment
Tools
-
declaring a conflict of interest
-
whistleblowing mechanisms
-
contractor qualification and auditing procedures
-
registering business gifts and event invitations
If you become aware of any violation of NLMK anticorruption requirements, please report it to
NLMK Independent Compliance Helpline
We guarantee that your report will be given due consideration. We also guarantee confidentiality and protection against any form of retaliation to any person that reported a violation in good faith. Your report can be anonymous.