5.12
Conflict of interest prevention and resolution policy
To discover and prevent any conflicts of interest in OGK-2, the following measures are taken:
- analysis and systematization of information on the chain of contractors owners, including beneficial (as well as ultimate) owners are made, confirmation documents are mandatorily requested, according to which verification measures are taken to ensure the reliability of the information provided;
- the Commission on the Conflicts of Interest of OGK-2 is available whose members are approved by Order of OGK-2 PJSC No. 141 dated May 23, 2019 subject to the Regulation about the Commission on the Conflicts of Interest (approved by Order No. 1307 dated December 03, 2014). Regulations on the Operating Procedure for Interaction with Contractors to Receive Information on the Chain of Owners, including Beneficiaries (as well as Ultimate Owners), and/or on the Composition of the Contractor’s Executive Bodies were approved at OGK-2 by order No. 926 dated September 22, 2014;
- To prevent the conflict of interest, potential candidates to fill in vacant positions in the Company, as well as employees of OGK-2 and their close relatives are examined in strict compliance with the applicable laws on personal data protection.
Commission on the Conflict of Interest
The Commission on the Conflicts of Interest includes 5 members. The Chairman is Deputy Managing Director of OGK-2 for Corporate Protection Mr. Igor Yuryevich Podkin.
The Commission main goals are:
- making decisions on transactions when the contractor does not disclose any information about the chain of owners in full or refuses to disclose such information at all;
- making decisions to settle any conflict of interest in case they arise;
- development of tactics and methods to identify, prevent and resolve any conflicts of interest.
In 2020, 10 meetings of the Commission on the Conflicts of Interest were held, where 13 issues were considered.
No conflict of interest was established among the members of the Board of Directors and executive bodies of the Company.
Most issues considered in 2020 were related to making decisions on Company’s transactions in cases where contractors did not fully disclose information about the ownership chain or refused to disclose such information.