Anti-corruption Declaration
We will significantly increase the efficiency of employees by providing them with the opportunity to work with automatically generated reports.
Anti-corruption Declaration
Anti-corruption declaration involves employees and their family members providing information about income, property, and property-related obligations. The current declaration procedure was not created from scratch. Starting from 1992, the obligation of Russian officials to provide information about income, property, and property-related obligations was consistently established in a series of regulatory legal acts. By the time the Federal Law «On Countering Corruption» was adopted, the obligation to declare income and property was prescribed, in particular, in the Federal Constitutional Law of 17.12.1997 No. 2-FKZ «On the Government of the Russian Federation» and in the Federal Law of 27.07.2004 No. 79-FZ «On the State Civil Service of the Russian Federation.» Currently, any organization operating in the territory of the Russian Federation is required to take appropriate measures to prevent corruption in accordance with the requirements of Article 13.3 of the Federal Law «On Countering Corruption.»What You Need to Know?
The list of individuals required to provide information about income.
- It is essential to apply the declaration requirements not only to employees but also to their family members. This should prevent officials from transferring expensive property to relatives, hiding it from oversight bodies.
Indicators of Corruption
- Anti-corruption declaration primarily aims to identify so-called "corruption indicators." Corruption indicators refer to information indicating possible corruption offenses by employees. One of the most well-known, though not the only, corruption indicator is the discrepancy between an employee's expenses and income. For example, based on declared information, it is assumed to track the correspondence of the value of transactions for the acquisition of real estate, vehicles, securities by the employee and their family members to an amount exceeding the total income of that person and their spouse at their main place of service (work) for the preceding 3 years before the transaction. Another indicator could be the acquisition of property by an employee or their close relative at a significantly reduced price.
Conflict of Interest
- Declarations are often used not only to detect corruption indicators but also to identify conflicts of interest. They can be a valuable source of information about the organizations (both commercial and non-profit) associated with the employee and their relatives. A common Income Statement contains information that can be used to detect conflicts of interest. This includes a list of organizations whose securities are owned by employees and their family members, the names of credit institutions where declarants' funds are placed, information about creditors and debtors of employees and their family members.
What Risks?
Organizations that implement anti-corruption declaration face the following risks:Employee Burden
Expanding the circle of individuals required to submit declarations leads to a significant increase in the workload on employees responsible for collecting, storing, and verifying income information provided by declarants. Employees may not be able to complete checks in full within the set deadlines.
Information Leakage
Public disclosure or leakage of information about family members, as well as the sources and amounts of their income, expenses, and property obligations, can be exploited for unlawful purposes.
Experience with PJSC «RusHydro»
PJSC «RusHydro» was one of the first large companies in the real sector of the economy to join the Anti-Corruption Charter of Russian Business. For the company, an Automated Information System of Affiliation (AISA) was developed and implemented in industrial operation in 2012. AISA operates on the «Vector Plus» platform and is a solution that allows for effective detection of hidden information and conflicts of interest. The system identifies both declared and undeclared participation in a legal entity that has transactions with any company in the RusHydro Group.
The software uses automated processes for collecting information and conducting comprehensive checks to detect conflicts of interest within the Group. It also automates the generation of reports. The AISA system allows for quick verification of company employees’ affiliations and their family members based on a centralized database of counterparties, counterparty beneficiaries, and data from the Unified State Register of Legal Entities (EGRUL). Confidential and personal data are protected in accordance with the law 152-FZ and stored on the company’s servers. The solution is used annually to check over 70 thousand employees and 150 thousand counterparties.