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Compliance and Anticorruption in Russia and CIS, 6th Annual Conference, June 2019, Moscow


DAY 1: THURSDAY, 27 JUNE 2019 
Creating counteraction to fraud and corruption system in “Know Your Employee” in the subsidiaries and affiliates of Rosseti Group
Aleksandr Batalov, Director of department of economic security and anti-corruption
  • Risk factors assessment inherent in the subsidiaries and affiliates activities
  • Relaying corporate compliance principles and standards to subsidiary companies and depended societies
  • Employee’s profile - "Know your employee” principle: Internal Due Diligence ProceduresExamples of facts found
    • Compliance with Due Diligence procedures at recruitment stage
    • Should we conduct a Due Diligence process for existing employees (gambling, drugs, debt, etc.)?
    • Conflict of interest identification
    • Qualifications falsification by managers (education, certificates, etc.) 
Anti-corruption procedures implementation process coordination
Yuliya Nikolaeva, Head of legal and compliance
Sergey Khripyakov, Head of compliance
METRO Cash & Carry
  • Departments engaged in Anti-Bribery & Corruption Procedures
  • Procedures and policies development: Separation of powers, challenges encountered and solutions
  • Employee training
  • Assessing Corruption Risks: Methods and Results
  • Changes to the Anti-Bribery & Corruption System
“Tone from the top” as one of the most important elements of creating a compliance culture and engaging employees from the top to bottom in order to minimize the corporate violations risks
Vera Kolesnik, Legal director
  • Compliance with the top management ethical and business standards by example
  • Management role in the anti-corruption compliance process implementation at all organization levels
  • Management interest in encouraging employees to effectively comply with the compliance program.
  • Prospects for the compliance programs development and the expected results from the "Tone from the top"
Third party reliability analysis and assessment; compliance risk management
Artur Allaliev, Legal department director
Kia Motors Russia
  • The most common risks associated with the third-party bad faith
  • Compliance with the law requirements in carrying out the third-party reliability assessment
  • Specific compliance issues in relationships with resellers and sales agents
  • Compliance risks minimization prior to entering into an agreement
  • Tracking contractual relations with third parties
Real-life experience in the efficient Compliance Department creation, PepsiCo Group
Ekaterina Cheburkova, Compliance director
  • Key compliance-defining regulations
  • Preventive control and corporate compliance procedure automation goals
  • Creating Compliance Department from “scratch” and main challenges
  • Compliance Department place in the company structure; the department interaction with other departments and business units
  • Compliance role in Company: From consultancy to ‘Veto’
Practical experience in implementing the anti-corruption policy of Russian Railways - an organization established to fulfill the tasks assigned to the Russian Government
Maksim Trushin, Deputy director for anticorruption
  • Issues of anti-corruption restrictions, prohibitions and responsibilities introduction in JSC “Russian Railways”
  • Anti-corruption procedures implementation in the company
  • Anti-corruption activities digitalization
  • Implementing anti-corruption mechanisms and procedures in subsidiaries and subsidiaries of Russian Railways
Informal leaders role in building a compliance culture in the company. The Compliance Program of Ombudsmen in Nokia 
Svetlana Makarova, Lead compliance counsel, europe
  • Creating corporate culture in the company and the violations reporting policy / free informing as its element.
  • Informal Leaders and Compliance Ombudsmen in Nokia:
    • Concept
    • History, implementation
    • Challenges, successes, and results
From compliance to business ethics: Life hacks from VimpelCom
Ilsur Akhmetshin, Vice-president for compliance
Compliance Department
Petr Androsenko
Yuliya Glubokaya
Anton Chazov
Svetlana Snezhko
  • "Time H” ethics project - 3 directions of our system approach
  • Ethical leadership from the top. Seven brave. How does it work?
  • The lessons of Yaroslav Chestny. 3 thousand managers discuss ethical and compliance dilemmas in their teams.
  • Online School of Business Ethics for 5 thousand heads of sales offices. Learn from a real ethical experience.
  • 72 hours of moral satisfaction: professional education for a corporate business ethics team
  • Ethical web series: Made in VimpelCom.  8 episodes so far, what's next?
  • Ethics Index - What do 15,000 surveyed VimpelCom employees think?
  • Ethical audit in VimpelCom: For the first time in the country, an external independent assessment by 250 criteria
Compliance commitee tasks and role in the compliance risk management process
 Andrey Nikomarov, Head of ethics and compliance
Johnson & Johnson
 Stakeholder management as part of the compliance system
Aleksandr Rudakov, Head of compliance
  • Using agile methods for timely compliance risks assessment
  • Methods for Deploying a Stakeholder Management Program
  • Information collection and analysis, interaction with other compliance system elements
  • Changing the Compliance Department reputation
Corporate compliance control system efficiency monitoring
Julia Larina, Regional compliance canager
  • Monitoring types: Three monitoring lines: Role distribution within the Company
  • Approaches to monitoring: Activities selective testing or "adaptive" monitoring
  • Specific verification of anti-corruption program requirements fulfillment
  • Testing the effectiveness of control procedures aimed at preventing the company's key risks
DAY 2: FRIDAY, 28 JUNE 2019 
Assessing the anti-corruption compliance program efficiency and ensuring continuous program improvement
Nikita Polozov, Head of legal department
Nadezhda Zotova, Head of Compliance
Jones Lang LaSalle, Russia & CIS
  • Efficient program concept and elements Efficiency assessment as per US Sentencing Guidelines and other recommended documents
  • Compliance control system efficiency evaluation methods Deming cycle application for compliance purposes
  • Ways to assess efficiency. Types of checks
  • Roles and functions distribution during the program efficiency assessment
  • Selecting program elements to be checked and verifying of compliance with various anti-corruption compliance program requirements
  • Using questionnaires for self-assessment purposes
  • Adaptation of universal approach to anti-corruption compliance program efficiency assessment to corporate specifics and needs
  • Regular anti-corruption compliance program review and updating as a result of its efficiency assessment
Compliance risk related control and monitoring system in HEINEKEN
 Tatiana Smirnova, Senior legal and compliance officer
  • What do we mean by "compliance"? Implementation experience
  • Compliance automation
  • Legal Compliance System: Responsibility Matrix, Risk Assessment, and Control
  • Inspections of state bodies: Management and control system  
Main directions of the Anti-Corruption Policy implementation in RusHydro Group
Elena Schegoleva, Director of internal control and risk management - chief auditor
  • PJSC RusHydro Group Anti-Corruption Program: Activities organization and development routes
  • Commission of Ethics as a tool for conflict of interests prevention/resolution, ensuring that employees comply with corporate ethics
  • Increasing the trust in the Hotline through effective work with appeals
Hotline on anti-corruption issues - practical issues of operation
Dmitry Gorbatov, Head of corporate regulation and control 
Trading company "Megapolis"
  • The positioning of hotlines and notification mechanisms within the compliance program
  • Ensuring the reception, accounting and processing of corruptive information and its objective evaluation
  • Analysis of information for significant violations
  • Stimulating employees to use hotlines and notification mechanisms
  • Do you have an adequate informer protection in place?
  • Hotline reporting to Top Managers
Comprehensive assessment and ways to reduce compliance risks in M&A transactions
Anton Pekhterev, Senior compliance manager
  • Determining the compliance risk check depth of the acquired company business practice including relations with Russian officials and the cash use in the business conduct, contracts with intermediaries
  • Awareness of the merge object on corruption risks and judicial practice
  • Measures to be taken in case the problems are identified the course of a legal due diligence prior to merge and acquisition
  • Cases requiring opinion request on the expediency of acquiring an object from foreign regulatory authorities
  • Specific issues arising after the M&A object acquisition
Creating an integrated internal control system for anti-fraud and anti-corruption in the company 
Karine Kocharyan, Country division controller
  • Internal procedures and processes specification: the way it works in real life
  • Control procedures and risks ranking based on their effect on the final result of every business process and overall company operation.
  • Distribution of management and controlling bodies roles in Internal Control System improvement
  • Identifying Internal Control System bottlenecks, developing recommendations, related risks analysis
  • Cases of Management participation in the Internal Control System of the company
Remote learning in compliance and business ethics: What to look for?
Margarita Khomenko, Compliance control director
X5 Retail Group
  • Which approach shall we choose?
  • How to convey the ideas of the rules and documents?
  • How to choose the audience within the company?
  • Show test and visualization questions options
Integrated security management when working with contractors: systematic approach
Svetlana Mochalina, Head of risk management department (legal, internal audit, compliance)
L’Occitane Ru
  • Violations prevention: selecting contractors and reliability assessment, internal control system
  • Violations detections: audits, analytical procedures, hotline
  • Audit results documentation and analysis
  • Repeated due diligence and procedure to determine the checks periodicity
  • Criminal prosecution and liability for transactions with unreliable contractors
Due Diligence practical aspects. Work with existing and new contractors within the modern legal framework
Anatoliy Petrykin, Head of compliance
  • Research tasks and objects, reliability assessment criteria we shall pay special attention to
  • Due Diligence efficient implementation in the modern legal framework. Procedure, tools, and legal mechanisms for information collection on the contractor
  • Verifying existing contractors: Efficiency, necessity, frequency
  • Practical recommendations on the contractor verification process Distribution of duties between company departments
Development and inclusion of an anti-corruption clause when concluding agreements with contractors
Dmitriy Nikitin, Director of risk management
  • Anti-corruption (compliance-) clause: Legal status and regulation in the Russian Federation
  • The use of anti-corruption clauses in practice: Russian specifics
  • Anti-corruption (compliance-) clause: Risks and threats to normal conduct of business
  • What anti-corruption clause might be acceptable for a modern Russian company?
Business Ethics Code as anti-corruption program element, UC Rusal
Igor Lerner, Director of control, internal audit and business coordination
  • How to make the code of ethics work?
  • Anti-corruption Code of Conduct