On November 8, 2013, the Ministry of Labor and Social Protection of the Russian Federation issued the methodological recommendations on development and adoption of measures by organizations on preventing and combatting corruption. Recommendations are aimed at assisting businesses in complying with the requirements on development and implementation of anti-corruption measures determined by Article 13.3 of Federal Law No.273-FZ.

Federal Law No.273-FZ, in addition to set requirements on combatting corruption, provides the list of measures recommended for organizations, but does not explain how to implement them or where to start. The Recommendations are general practical instructions on taking the anti-corruption measures, they form a consistent approach to prevention and suppression of corruption in organizations, regardless of their forms, business areas, and other circumstances.

The Recommendations list all the corruption offences as defined by Russian Law. This will assist the companies in understanding what a “corruption offence” is, as this specific term is not included in the legislation. Recommendations also explain the operation of exterritorial foreign legislation, which allows Russian companies and their employees to be brought to justice for corruption.

For instance, in addition to explaining the term “conflict of interest,” the possible situations of conflict of interest and control policy of the conflict in an organization are provided. The document also includes explanations on development and implementation of the anti-corruption policy, recommendations on evaluation of corruption risks, and measures on preventing corruption during cooperation of a company with contracting parties.

The document is recommended for all companies as a guide to compliance with the requirements of Federal Law No.273-FZ. At the same time, the Recommendations will help organizations to form a unified corporate standard of ethical conduct and negative attitude to corruption, strengthen the commercial goodwill, improve their rating, acquire skills in corruption risk management and cooperation with contracting parties and state authorities.

Methodological recommendations on development and taking by organizations of measures on preventing and combatting corruption, dated November 8, 2013

Additional notes

Should any questions arise in connection with the above or if you need any additional materials, please contact Irina Onikienko, St. Petersburg Office of Capital Legal Services.

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