Ethical business

SIR Group strives to build open and honest relationships with stakeholders, paying great attention to the promotion of business ethics, unconditional compliance with legal requirements, strict observance of human rights and the effectiveness of the anti-corruption system.

Guiding ethical principles

SIR Group strives to build open and honest relationships with stakeholders, paying great attention to the promotion of business ethics, unconditional compliance with legal requirements, strict observance of human rights and the effectiveness of the anti-corruption system.

Trust:

During its existence, SIR Group has managed to gain the trust of counterparties and customers. Having built friendly partnerships with its shareholders, investors and employees, the Group is determined to maintain, strengthen and develop them in the future.

Openness:

A transparent information policy not only guarantees the right of all interested parties to receive reliable and up-to-date information about the activities of SIR Group, but is also one of the most important components of the Company's corporate culture.

Respect for people:

The personnel policy is expressed in providing equal opportunities to all employees regardless of their national and religious affiliation, political views, personal beliefs, gender and age.

Professionalism:

All decisions are made on the basis of properly verified data and professionally sound judgments.

Impartiality and objectivity:

All decisions, including the selection of counterparties, partners, the formulation of terms of interaction with them, personnel and administrative decisions, are carried out on transparent and fair market conditions without unreasonable preferences or prejudices, as well as on the basis of professionally sound judgments.

The company has an anti-corruption management process based on the provisions of the main regulatory documents:

• The "Prevention and Counteraction to Corruption" policy defines the basic principles and requirements in the field of anti-corruption, contains a general description of all the key elements of the anti-corruption system and procedures implemented in SIR Group in order to prevent corruption.
• The Anti—Corruption Concept is an appendix to the "Prevention and Combating Corruption" Policy, which systematizes the main approaches, procedures and tools used in SIR Group to prevent/combat corruption and respond to corruption offenses.
• The Code of Ethics contains the key principles of interaction within the Group, with customers, the public and government agencies, as well as requirements for compliance with applicable legislation.
• The Internal Audit Code regulates the administration of the Unified Hotline, as well as the conduct of inspections of compliance with the requirements of anti-corruption legislation and internal procedures in SIR Group.
• The Regulation on conducting official investigations defines the procedure for organizing and conducting events aimed at a complete and objective investigation of facts, events and circumstances that have signs of an illegal act, timely identification and prevention of conflicts of interest, corruption components in the activities of SIR Group.

Anti-corruption

SIR Group has a constantly improving anti-corruption system that combines organizational, economic, legal and informational measures.

In its daily activities and in the implementation of projects around the world, Segezha Group adheres to the principle of zero tolerance to corruption in all its forms and manifestations. This principle applies to interaction with all interested parties, including participants in procurement procedures, investors, counterparties, government representatives, subsidiaries and other persons.

Control over compliance with the requirements of the anti-corruption system is carried out by the Security Department together with the Internal Audit Department. Prevention of corruption violations is the responsibility of all SIR Group employees. Employees undergo periodic training and testing on corporate ethics and anti-corruption requirements, including studying the procedure for submitting an Ethical Declaration on cases of conflicts of interest. All candidates for vacancies undergo a business reputation and reliability check, and new employees are instructed on anti-corruption measures in order to familiarize themselves with the main provisions of the Group's regulatory documents.