3.3.6 Anti-corruption Policy and Enforcement of Economic Security of Operations

The anti-corruption policy of PAOPublic Joint-Stock Company Rosseti and its subsidiaries is a single strategic document of PAOPublic Joint-Stock Company Rosseti and its subsidiaries that defines the single approach of the Rosseti Group to elaboration and implementation of measures to prevent and combat corruption. The goal of the anti-corruption policy is a single approach to implementation of the Federal Law^[40], with regard to elaboration and implementation of measures to prevent and combat corruption: exposure and subsequent elimination of corruption factors (corruption prevention); exposure and prevention of corruption-related and other offences; mitigation and (or) liquidation of consequences caused by corruption-related and other offences, as stated in the Russian Administrative Offence Code^[41].

The Company has established the following system for disclosure of information on conflicts of interest:

• initial disclosure of information on conflicts of interest upon employment or transfer to another position;
• annual disclosure of information on conflicts of interest as of 31 December of the respective year (declaration campaign);
• notification by employees of the occurrence of a personal interest in the performance of official duties that leads or may lead to a conflict of interest.

Initial disclosure of information on conflicts of interest ensures verification of declared information and preparation of the relevant conclusion regarding the examination of a candidate seeking to fill a position, thereby preventing the emergence of pre-/conflict situations within the Company. During the reporting period, 6,245 job applicants seeking positions within the Company and its subsidiaries were reviewed and examined. Twelve pre-conflict situations related to direct subordination of employees in family relationships were identified. Measures for annual declaration of conflicts of interest by employees of the Company and its subsidiaries (AOJoint-Stock Company «EESK») were fully implemented using the electronic declaration subsystem of the «Automated System for Analysis and Collection of Information on Beneficiaries» (AS ASIB). As a result of the 2024 declaration campaign, three pre-conflict situations were identified, which were reviewed and resolved at a meeting of the Commission for Compliance with Corporate Ethics Standards and Conflict of Interest Resolution of PAOPublic Joint-Stock Company Rosseti Ural.

The Company has established the following hotline communication channels:

• Hotline telephone +7(343)293-21-83. The hotline operates 24/7 without days off in automatic mode with voice messaging capability;
• Feedback form for reporting corruption and fraud incidents, posted on the Company’s website. The corruption and fraud feedback form operates in automatic mode, enabling submission of text messages with copies of supporting documents, including the option for anonymous submissions.

Information stands titled “Corruption-Free Territory” are displayed in the offices of the Company’s executive apparatus, branches, and subsidiaries, as well as in customer service centers, containing detailed information on all available methods for submitting reports to the Company regarding potential corruption incidents.

During the reporting period, the Hotline received a total of 12 messages (6 anonymous), with only 1 message containing information on potential corruption incidents. Preliminary verification measures confirmed that the facts cited in the message were unsubstantiated.

The expert staff of the Company’s responsible division conducts examinations of procurement participants’ applications for completeness of information disclosure, veracity, identification of affiliation indicators, conflicts of interest, pre-/conflict situations, and other abuses associated with positions held within the Company.

During the reporting period, participation was recorded in 1,923 procurement procedures. Examinations of the Company’s procurement participants were conducted for 4,196 cases. Following competitive procurement procedures, negative conclusions (expert opinions) were issued in respect of 227 participants. Based on security division conclusions, 35 procurement procedures in the amount of RUBruble 92 million were declared failed due to all procurement participants being found non-compliant with the tender documentation requirements and failure to adhere to the Anti-Corruption Standard for Procurement Activities.

PAOPublic Joint-Stock Company Rosseti Ural participates in collective initiatives to counter and prevent corruption, specifically having been a signatory to the Anti-Corruption Charter of Russian Business since 2015. Accession to the Charter and consistent implementation of its provisions serve as confirmation of the Company’s adoption of appropriate anti-corruption measures as required by international legal standards and Russian legislation on corruption prevention and counteraction.