Ethics and statutory compliance

In 2017 work continued on implementing the provisions of the LUKOIL Group Antimonopoly Policy approved in 2016. The Russian subsidiaries of the Group have developed and adopted in-house regulations on antimonopoly compliance, and appointed individuals responsible for monitoring compliance with antitrust legislation. Work has been carried out to inform employees about the provisions of the LUKOIL Group Antimonopoly Policy and the need to adhere to these norms in their day-to-day activities. Monitoring compliance with this document, as well as other in-house regulations aimed at preventing violations of antitrust legislation, is entrusted to the Working Group supporting relations of LUKOIL Group subsidiaries and the Federal Antimonopoly Service of the Russian Federation (FAS) and its regional authorities on issues concerning production and commercial activity.

In 2017 the number of violations of antitrust legislation by LUKOIL Group subsidiaries declined significantly, which was related to the consistent implementation of the LUKOIL Group Antimonopoly Policy, as well as the stabilization of law enforcement practice in this area in Russia.

In accordance with the Code of Business Conduct and Ethics of PJSC LUKOIL, the main principles underpinning the business activity of a LUKOIL Group entity are zero tolerance towards corruption in any form or manifestation, and compliance with the antitrust legislation of the countries where the Group operates.

Compliance with antitrust legislation by LUKOIL Group subsidiaries
2015 2016 2017
Number of completed cases of antitrust legislation violations 15 16 3
Total monetary amount of material penalties for antitrust legislation violations, RUB million 14.30 0.70 1.10

Note. Administrative fines exceeding RUB 100,000 are considered to be material penalties. The total monetary amount of fines indicator reflects the number of cases completed in the corresponding reporting period, including those commenced in previous years. (The process for considering cases until the issue of the final decision can take varying periods of time.)