Ethical principles set forth in the Code of Business Conduct and Ethics of PJSC LUKOIL APSTRIM constitute a foundation of the Group's corporate culture and cover all aspects of business conduct. The Company extends the rules of ethical conduct to relations with its partners, vendors and contractors informing them of its corporate rules and strongly suggests them to familiarize themselves with its Code of Business Conduct and Ethics.

The Code of Business Conduct and Ethics contains rules that are consistent with the best international practice and standards of business ethics.

The main mechanism for monitoring compliance with the corporate ethics rules is the Business Ethics Commission established to review respective issues and violations of the provisions set forth in the Code of Business Conduct and Ethics. The Commission is chaired by the President of PJSC LUKOIL APSTRIM. In case of situations requiring attention of the Company management respective information is provided to the chairman of the Commission.

Concerned parties can contact the Business Ethics Commission via any available means of communication (by sending an e-mail to the dedicated address, ethics@lukoil.com, available around the clock, or a written request to the Business Ethics Commission, or by phone). The appeals are accepted in all languages of the countries where the Group operates 

The Company guarantees the confidentiality of any person who has reported a violation. In addition to the Commission, employees can also report violations of the Code or their rights to respective trade union bodies. 

 The Code of Business Conduct and Ethics is a corporate document and therefore all employees of LUKOIL APSTRIM Group entities, including foreign-based ones, must comply with the corporate ethics rules. General directors of respective entities are responsible for making sure that their personnel comply with the local regulations.

In case of proven violations of the local regulations by the employees of the Group entities, a variable part of remuneration (monthly bonus/annual bonus) may be reduced. The amount to be reduced depends on significance of the identified violation.

PJSC LUKOIL APSTRIM has endorsed LUKOIL APSTRIM Group Antitrust Compliance Policy, approved by the Federal Antimonopoly Service of the Russian Federation. The newly adopted Policy intends to guarantee both PJSC LUKOIL APSTRIM and other companies of the Group, registered in Russia, comply with the antitrust law. 

The Policy provides for a package of legal and administrative tools to enforce antitrust compliance, defines business activities across LUKOIL APSTRIM Group that are most prone to antitrust risks and establishes measures that disclose those risks together with their causes and origins as well as prevent any potential failures to comply with the antitrust law.

Antitrust compliance being an integral part of its corporate values, LUKOIL APSTRIM Group assumes any breach of the antitrust law unacceptable and makes every effort to prevent and curtail a violation. No business interest of no LUKOIL APSTRIM Group company may serve an authorization to infringe the antitrust law. 

LUKOIL APSTRIM Group Antitrust Compliance Policy is equally binding for PJSC LUKOIL APSTRIM, LUKOIL APSTRIM Group companies and their employees.

Taking every step to facilitate and arrange for antitrust compliance, LUKOIL APSTRIM Group, for instance, has established a working group of top-tier managers, supervising the operation of the corporate antitrust compliance system, organizes regular training events that build on industry-specific aspects of LUKOIL APSTRIM Group operations and raise awareness of applicable law cases and requirements. LUKOIL APSTRIM Group also tracks the course of actions of antitrust authorities and advises employees on conduct patterns, acceptable antitrust-wise. 

LUKOIL APSTRIM Group is committed to the zero tolerance principle which means that no form of corruption can be tolerated in its operations, irrespective of the jurisdiction and local laws even if they allow certain forms of corruption (e.g. facilitation payments).

The Company is not engaged in corrupt practices nor does it promote them, including on the part of its business partners, and uses its best efforts to prevent such acts. The practice of paying compensations or using other incentives when dealing with public officials is absolutely unacceptable for the Company. 

The Anti-corruption Policy sets common principles, goals and objectives to combat corruption. The Policy also describes key actions to mitigate risks of corruption in the following situations:

• gifts and hospitality expenses;

•  conflict of interest and sponsorship, interaction with business partners, participation in politics, interaction with competitors, public authorities, etc.

Employees must acknowledge in writing that they have read the Policy as part of the hiring process.

Based on the due diligence principle, the Company checks the trustworthiness of counterparties of LUKOIL APSTRIM Group entities. An information management system was implemented for counterparty due diligence which allows for assessing the level of risks related to Russian counterparties at the stage of the conclusion of contracts for goods, work and services as well as at the stage of their execution.  The system allows for automating the due diligence process and reducing the impact of the human factor on the assessment of such risks.

A dedicated Hotline (anticorruptionline@lukoil.com) was created which can be used by any person to report actual or alleged violations of anti-corruption laws and/or provisions of the Policy as well as express his/her wish to assist in investigations.