5.13

Anti-Corruption Policy

At OGK-2, anti-corruption measures are implemented in strict compliance with the applicable Russian law:

• Federal Act No. 273-FZ dated December 25, 2008 “About Fighting Corruption”;
• Decree of the President of the Russian Federation dated April 02, 2013 No. 309 “On the Measures Aimed at Implementation of Specific Provisions of the Federal Act “About Fighting Corruption”;
• Order No. VP-P13-9308 of the Chairman of the Government of the Russian Federation dated December 28, 2011;
• departmental and local regulatory acts.

OGK-2 has standards and procedures developed to ensure the Company’s responsible operations, including procedures adopted to identify and prevent corruption, including bribery of foreign officials.

Systematically and routinely measures are taken to ensure compliance with the corporate interests of the Company and minimize risks of economic damage. A set of measures has been developed and is implemented on a daily basis to identify, suppress and prevent corruption offenses and minimize their adverse consequences. Subject to the corporate procedures, control over the procurement operations arrangement, contractual work, continuous incoming control of goods and materials, as well as other activities aimed at ensuring compliance of the Company’s employees with the applicable law and local regulations are performed. No facts of corruption were detected following the results of 2020.

Since 2014, a hotline has been operating in Gazprom PJSC aimed at fighting fraud, corruption and theft in companies included in Gazprom Group. All appeals received through it are carefully checked and analyzed.