Case study: How Polyus combats corruption
Polyus is the largest gold producer in Russia and one of the largest global gold mining companies, operating a portfolio of well-established mines located in remote regions across Russia, such as Krasnoyarsk Territory, the Irkutsk and Magadan Regions, and Yakutia. Polyus is focused on combating corruption and creating an effective anti-bribery and corruption system, so as to build transparent and honest relationships with its stakeholders. Tweet This!
This case study is based on the 2018 Sustainability Report by Polyus published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
Polyus strictly complies with both domestic and foreign anti-corruption laws, including the UK Bribery Act, and has adopted an attitude of zero tolerance towards any form of bribery and corruption. In order to combat corruption Polyus took action to:
- implement an Anti-corruption Policy
- provide anti-corruption training
- establish a security hotline
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With this case study you will see:
- Which are the most important impacts (material issues) Polyus has identified;
- How Polyus proceeded with stakeholder engagement, and
- What actions were taken by Polyus to combat corruption
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What are the material issues the company has identified?
In its 2018 Sustainability Report Polyus identified a range of material issues, such as economic performance, environmental compliance, occupational health and safety, effluents and waste, emissions. Among these, combatting corruption stands out as a key material issue for Polyus.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Polyus engages with:
To identify and prioritise material topics Polyus engaged with its stakeholders through the following channels:
Stakeholder Group | Method of engagement |
Shareholders, lenders, bondholders
| · Annual general meetings · Regular hard-copy and e-communications · Regular meetings with institutional shareholders · Access via Polyus’s website www. polyus.com |
Government and regulators
| · Agreements on social-economic partnerships · Charity and sponsorship initiatives · Conferences and forums · Memberships of associations (in addition to ICMM) |
Employees
| · Direct communications with employees through immediate supervisors and management · Corporate newspaper Territory of Polyus · Internal web portal · Operation-based newsletters · 24/7 Hotline · Confidential feedback boxes · Corporate sports and cultural events, professional competitions · Volunteer projects |
Local and indigenous communities
| · Newsletters and targeted communications · Public hearings and meetings · Confidential feedback boxes · Charity activities · Social programmes |
Suppliers and contractors
| · Tenders · Contractual relationships · Workshops |
NGOs and industry organisations | · Regular interactions with relevant national and international organisations |
Media
| · Press releases, briefings · Presentations and interviews · Site visits |
What actions were taken by Polyus to combat corruption?
In its 2018 Sustainability Report Polyus reports that it took the following actions for combatting corruption:
- Implementing an Anti-corruption Policy
- Developed in 2011, Polyus’s Anti-corruption Policy sets out 10 anti-corruption principles, is based on both Russian and international regulations in the field of anti-corruption and integrity and reflects the risk-orientated approach to anti-corruption adopted by Polyus. Polyus regularly reviews and updates its Anti-corruption Policy to support the continuous improvement of its anti-corruption system and to comply with all legislative updates and amendments. The Anti-corruption Policy applies to all Polyus employees, regardless of the position they hold, as well as entities associated with Polyus and its activities, including contractors, suppliers, agents, and consultants. When beginning their employment, all workers are made aware of the Anti-corruption Policy and other documents related to anticorruption initiatives within Polyus. New hires must also sign an additional document that confirms that they have been made familiar with these documents. In relation to third parties, Polyus carries out a detailed risk assessment and analysis of each counterparty and checks each legal transaction. In addition to standard anti-corruption clauses in contracts, Polyus has also established what is not permitted within the framework of contractual relationships, and reserves the right to conduct an audit of a counterparty, as well as the right to unconditionally withdraw from a transaction should there be any anti-corruption violations.
- Providing anti-corruption training
- Since 2017 a new distance learning course on anti-corruption has been run at all Polyus Business Units, with employees engaged in business processes related to corruption risks identified as the target audience. The main aims of the course are to:
- familiarise employees with the main norms of existing anti-corruption legislation and corporate expectations
- examine corruption-related case studies
- make sure that employees are made thoroughly aware of Polyus’s Anti-corruption Policy, as well as regulatory compliance requirements that apply to officials
- In 2018, 4,637 employees at the Managing Company and Business Units completed the distance learning course on anti-corruption, or 91% of the target audience. Polyus also provides considerable training for employees involved in anti-corruption activities, in order to boost the level of employee competencies in this area and to further improve its anti-corruption system. For example, during 2018 a number of Security & Asset Protection Department employees received International Compliance Association (ICA) certification.
- Establishing a security hotline
- A security hotline communication system is operational in all Polyus’s Business Units and subsidiaries, and is an effective and popular communication channel for both internal and external stakeholders. The main aim of the hotline is to serve as a channel for identifying, preventing, and minimising corruption risks, as well as preventing reputational and economic damage to Polyus’s interests and assets. Another objective of the security hotline is to receive and analyse human rights and business ethics-related concerns from Polyus’s stakeholders. Polyus makes sure that the security hotline is easily accessible. Stakeholders can submit messages via a mailbox, electronic mailbox, a free-of-charge hotline number, or in person. In order to facilitate the process of submitting messages and complaints, confidential mailboxes are installed at Business Units, Support Services, and the Managing Company. Polyus makes significant efforts to make sure that all stakeholders are fully aware of the existence of the security hotline, with hotline-related data published regularly in internal newspapers and placed at information desks. Polyus also distributes specially designed leaflets on how to use the hotline in its Business Units, Support Services, and Managing Company offices and promotes an anti-blame policy in relation to the internal security hotline in terms of any violations of anti-corruption laws or business ethics. Subject to the timely provision of information, Polyus ensures the confidentiality of a person submitting a report. This approach is enshrined in the Anti-corruption Policy and the Code of Corporate Ethics, and is also promoted in anti-corruption posters. Polyus carefully examines each report before taking any action, and makes sure that those that have raised concerns receive appropriate feedback. The approach to processing received messages is formalised in the Provision on the Security Hotline Communication System Organisation and Operation. Responsible employees aggregate and analyse statistics on received messages and present the results of their analysis on a quarterly basis. In the event that a message relates to ethical conduct, employment relationships, or wages, the message is forwarded for analysis to the HR Department. Each year the number of messages received through the security hotline grows, thus demonstrating that stakeholders view it as a reliable communication tool. In 2018, the security hotline received 336 messages on line one and 42 messages on line two (from August 2018). The bulk of inquires related to infringements of employee and counterparties’ rights, business ethics, the requirements of internal regulatory documents, and misappropriations. Polyus reviewed each case and organised an investigation in cases where violations were confirmed. The 2018 results indicated that the number of signed messages has grown more significantly than the number of anonymous messages, which points to an increase in the trust of stakeholders as well as the increasingly transparent nature of communications. In the reporting year, no corruption-related lawsuits were brought against Polyus or its employees.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-1 Operations assessed for risks related to corruption
2) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
3) Disclosure 205-3 Confirmed incidents of corruption and actions taken
Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:
- Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
- Business theme: Anti-corruption
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
- Business theme: Anti-corruption
Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:
- Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
- Business theme: Anti-corruption
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References:
1) This case study is based on published information by Polyus, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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