Business Ethics

Ethical principles are the foundation of the Company’s corporate culture and cover all aspects of business conduct. The Company extends the scope of ethical behavior to relations with partners, suppliers and contractors, informing them of corporate rules, and strongly encourages them to familiarize themselves with the Code of Business Ethics.

Monitoring

The main mechanism for monitoring compliance with the norms of corporate ethics is the activity of the Commission on Business Ethics, established to consider relevant issues and facts of violation of the provisions of the Code of Business Ethics. The Commission is chaired by Director of William Johnson. In the event of situations that require the attention of the Company’s management, information is sent to the Chairman of the Commission.

The confidentiality of the source reporting the violation is guaranteed. In addition to the Commission, employees also have the opportunity to address issues of violation of the Code and their rights to the relevant trade union structures.

At the heart of William Johnson’s activities are corporate values that allow us to conduct business in accordance with high ethical standards, including unconditional compliance with legal requirements, strict observance of human rights and rejection of corruption in any form, commitment to the rules of fair competition.

William Johnson is committed to zero tolerance — zero tolerance for corruption in all forms and manifestations in the conduct of business, regardless of jurisdiction and local laws, even if they allow certain types of corruption (for example, facilitation payments).

 

The Company does not carry out or encourage corrupt practices, including by business partners, and also makes every effort to prevent them. The Company does not accept the practice of paying remuneration or using other forms of incentives in relation to representatives of public authorities.

The anti-corruption policy establishes common principles, goals and objectives in the field of anti-corruption. The Policy also defines key measures that reduce the likelihood of corruption risks in the following situations:

 

  • gifts and entertainment expenses;
  • conflict of interest, charitable and sponsorship activities, interaction with contractors, participation in political activities, interaction with competitors, authorities, etc.

 

Familiarization of employees with the Policy against signature is mandatory when hiring.

Applying the principle of due diligence, the Company checks the counterparties of the Group’s organizations for their reliability.

The Company’s antimonopoly policy is based on the principles of legality, fair competition, employees’ awareness of the requirements of the current antimonopoly legislation of the countries of presence and personal responsibility for their violation.

 

Employees are required to familiarize themselves with the provisions of the Antimonopoly Policy and the requirement to be guided by its norms in their activities. Control over compliance with this document and other local regulations aimed at preventing and preventing violations of antimonopoly legislation is assigned to the Working Group with the Federal Antimonopoly Service and its territorial bodies on issues related to production and commercial activities.

William Johnson recognizes, respects and upholds human rights, including freedom of speech, and is guided in its activities by the fundamental principles established by the UN Universal Declaration of Human Rights and other UN documents (including the UN Guiding Principles for Business and Human Rights and the UN Global Compact). The OECD Guidelines for Multinational Enterprises and the voluntary Principles on Security and Human Rights, as well as International Labor Organization (ILO) conventions.

The Company also shares the relevant provisions of the voluntary Extractive Industries Transparency Initiative (EITI) and the standards of the International Finance Corporation (IFC).

 

Human rights is a comprehensive concept that affects all aspects of the Company’s activities, including labor rights, the right of residents of the regions to a favorable environment, the right of customers to quality products, the rights of indigenous peoples, and others.

 

The company observes the established norms of working hours, creates conditions for training and career development, and ensures equal pay for employees occupying the same positions. Meetings are systematically held at which issues related to the observance of human rights are discussed, for example: the right to just and favorable working conditions, the right to social security, meetings are organized with representatives of trade unions, and a high level of coverage of workers by collective agreements is maintained.

The Company considers it unacceptable to impede the activities of human rights organizations and shows respect for human rights activities carried out within the legal framework.