Internal Control and Auditing
Seeking higher business efficiency, the Concern continues to improve its internal control and auditing system, and takes anti-corruption measures.
The Concern provides for independent and unbiased operation of the Dedicated Internal Control Body (DICB), professional competence of its employees, and unrestricted and efficient performance of the entrusted functions.
In 2014 the DICB conducted 19 control activities using risk-oriented approach. They were performed by way of synchronizing audit elements with control and revision methods (“two-inone”). Audits are aimed at improving the reliability of internal control systems and risk management, providing comprehensive assessment of existing business processes, and are combined with verification of the legality and validity of specific business operations that are intrinsic to control and auditing activities. The application of disciplinary actions and fines to persons in breach contributes to increasing the level of responsibility. The combination of various methodologies permits us to perform tasks of the DICB in an extensive, comprehensive, and efficient way and achieve strategic goals of the Concern.
As a result of control activities in the sphere of international technical assistance, research and development work, labor remuneration, patent use, financing of investment projects, insurance, IT services, financial and economic activities of subsidiaries, etc. in 2014 recommendations were prepared in order to eliminate the deficiencies revealed and minimization of risk down to the acceptable level. Business process owners perform 379 organizational and technical activities (73% higher versus 2013). Fulfillment of such organizational and technical activities is under constant control of the DICB.
The Concern’s Arbitration Committee (hereinafter – the Committee) met its targets of pre-trial disputes settlement and ensuring procurement procedures legitimacy.
Committee’s priorities are: transparency, openness, and information availability. They are implemented by participation in the largest all-Russia forums (Atomex and Goszakaz), routine publication of reviews of the arbitration practice, and posting of each opinion of the Committee on the Concern’s portal.
The methodology on fulfillment of Committee’s opinions was developed and put into practice, permitting us to significantly increase quality, timeliness, and completeness of implementation of resolution of the Committee. The methodology is the first of its kind in the industry. As a result, the share of justified complaints versus reviewed complaints has decreased by one third, and versus the total amount of purchases of the division – almost by half. A set of measures on adjustment of activity of senior auditors – internal controllers of the Concern’s branches, operating NPPs.
The following are the key areas of development for internal control and audit: thorough control actions, increase in quality of reporting materials, review of organization processes and integration of appropriate, reliable, and efficient control procedures with allocation of responsibility of business process participants for their proper performance, and improvement of competencies and potential of employees of DICB.
In 2014 the main efforts of the Concern were aimed at formation of local regulatory base on anti-corruption, improvement of prevention measures focused on organization of good faith operation of the Concern, as well as performance of recommendations issued by Rosatom State Corporation.
In order to implement specific provisions of the National Anti-Corruption Plan for 2014-2015 the Concern approved and put into effect the Anti-Corruption Plan for 2014-2015. The Concern’s administrative orders determined officials and subdivisions responsible for work on prevention of corruption and other offenses, and appropriate duties are allocated to such officials and subdivisions. The Concern’s Ethics Code and the Unified Industry-Specific Procedure for Verification of Communications on Corruption and Other Offenses Received through Hot Line Channels were updated. The Guidelines on Analysis of Applications and Planned Transactions for Interest in Their Settlement were put into effect. Local regulations were adopted with a view to ensure anti-corruption practice of the external economic activities, as well as a number of local regulations increasing responsibility for preparation of unofficial financial and other reporting were introduced.
The Action Plan on Organization of Training and Legal Education of Concern’s Employees in the Matters of prevention and countering corruption was approved. The Action Plan provides for development of a training program for employees, and preparation of schedule and organization of training in educational institutions. In the reporting period 27 employees of the Concern attended training on the subject “Formation and Verification of the Initial (Maximum) Price during Procedure for Order Placement and Structural Analysis of the Pricing Mechanism of the Contracts Concluded in the Organizations of Rosatom State Corporation.
With a view to create conditions impeding corruptive behavior and thus reducing corruption level in the Concern, the development of standards and procedures ensuring good faith operation of the Concern is introduced in daily practice. First of all, this activity is aimed at ensuring transparency of transactions, openness of procurement procedures, prevention of bad faith competition, and exclusion (minimization) of corruptive risks during competitive processes for supply of equipment, and performance of work and services.
A number of collegiate bodies involved in review of main issues of financial and economic activity is created and currently functions in the Concern. Their meetings are held and accompanied by audio and video recording. In the reporting period Concern’s economic security subdivisions verified over 21,000 participants of procurement procedures for their compliance with the requirements of UIPS, including in terms of corruptive practices. As a result, over 2,600 breaches of the procurement procedures were revealed. With respect to 180 reported cases involving possible risks and threats, the Concern’s and NPPs’ management took preventive measures which permitted to avoid potential corruption risks and possible property damage totaling over 248 mln rubles.
In 2014 117 communications to the Hot Line and queries of people reporting corruption and other offenses were verified, and 33 of them were confirmed. As a result of the appropriate measures the breaches revealed were eliminated, and 42 employees of the Concern were subjected to disciplinary action.
In 2014 economic security subdivisions jointly with NPP subdivisions revealed and prevented 66 attempts to supply and use of equipment with signs of illegal origin at NPPs, including by way of substitution of such equipment with the legitimate equipment. The information on 13 revealed cases of supply of falsified products was supplied to law enforcement agencies for further legal evaluation.
In 2014 no cases of breach of anti-corruption legislation of the Russian Federation and requirements of industry-specific local regulations regulating anti-corruption activity resulting in imposing of any sanctions and fines or property damage for the Concern were revealed in the Concern.