Conflict of interest prevention and management

GRI 2–15

Preventing and resolving conflicts of interest remains a priority anti‑corruption area. We implement comprehensive preventive measures to identify, review, and eliminate potential conflicts of interest at all levels through stable identification systems and response mechanisms.

Our Corporate Governance Code, approved by the Board of Directors, includes a special anti-corruption section with conflict of interest prevention measures applying to all Company governance bodies.

The conflict of interest procedures for the members of Russian Railways’ Board of Directors are outlined in the Regulation on the Board of Directors of Russian Railways. Under the document, Board members must make decisions based exclusively on Company interests and cannot use their position or information for personal benefit or third-party interests.

All other Company employees must also prevent and resolve conflicts of interest according to our operating Regulation on Prevention and Resolution of Conflicts of Interest.

Regional Conflict of Interest Commissions as coordination bodies reviewed several situations. Following proceedings, 29 Company employees who had committed violations received disciplinary measures.

Our systematic awareness raising efforts have steadily increased employee initiative: more staff voluntarily declare potential conflicts of interest.

This positive trend indicates growing trust in our conflict of interest resolution system.