“Dori-Darmon” JSC Anti-Corruption PROGRAM

Section 1: Main Goals and Objectives of the Program

Chapter 1: General Rules

1. One of the main objectives of the Company is to prevent corruption and other offenses, identify, analyze and eliminate the causes and preconditions contributing to their occurrence in the “Dori-Darmon” JSC (hereinafter, the “Company”).

2. The main goal of the program is to ensure the rule of law in the Company's system, form an uncompromising attitude toward corruption among employees, avoid conflicts of interest, ensure the inevitability of liability for corruption offenses, and regulate relations in the sphere of combating corruption.

3. The main tasks of combating corruption in the Company's system are as follows

- Ensuring coordination of activities and interaction between the Company and its structural organizations in the fight against corruption;

- assessment and management of the risks of corruption;

- organization of development and implementation of measures aimed at increasing legal awareness and legal culture of employees of the Company and its structural organizations, formation of an uncompromising attitude towards corruption in the system;

- Ensuring more effective measures to identify corruption offenses, their prevention and elimination, elimination of the consequences, as well as the causes and preconditions that allow the manifestation of such vices;

- collecting and analyzing information on cases of corruption and their trends;

- improvement of legislative acts in the field of combating corruption, and preparation of proposals to improve work in this direction;

- ensuring international cooperation in the fight against corruption.

 

Section 2: Main Directions of the Program

Chapter 2: Organizational Measures to Prevent Corruption in All Areas of the Company System

4. Introduction by the officials and other employees of the Company and its structural organizations in their system of effectiveness of corruption prevention and combating corruption in the performance of their official or official duties, as well as its quality assessment systems.
5. In order to identify areas where there are risks of corruption in the activities of the Company and its structural organizations, it is necessary to conduct a social survey among employees on the Company's Telegram Channel and Facebook page on the theme “Overcome Corruption Together” and analyze the results of the survey to develop “road maps” aimed at eliminating factors of corruption.
6. Development of proposals to identify and manage corruption risks in the Company's system.
7. Ensure regular posting of information about vacancies in the Company and its structural organizations, as well as the requirements for candidates on the Company's website and in social networks.
8. Identify employees who have been effectively employed for a long time in one position in the Company and its structural organizations, and prepare proposals for the practice of their transfer to positions at least one level higher.
9. Implementation of a system for studying the social status of employees of the Company and its structural organizations. In doing so, forming a list of low-income, disabled and large employees and preparing proposals for a report on their status and, if necessary, considering measures for their financial support.
10. Develop mechanisms to ensure fair distribution of inventories within the Company and its structural organizations. In doing so, establish a procedure for the use of company cars and other tangible assets based on the workload and needs of employees.
11. Analysis of purchasing prices by regions and the republic in the context of each commodity item for purchases in the Company and its structural organizations, in order to achieve the most optimal pricing.
12. Create an opportunity to monitor the accuracy of labor remuneration and settlements in the Company and its structural organizations, and prepare proposals to expand the opportunities for employees to file complaints.
13. Conduct an inventory and analysis of the regulations governing the services provided by the Company and its structural organizations. At the same time, develop proposals to simplify complex services, eliminate norms that have corruption gaps.

 

Chapter 3. Forming an uncompromising attitude towards corruption in the Company's system and increasing the legal awareness and legal culture of employees

18. Preparation and distribution of information and analytical materials aimed at forming an uncompromising attitude towards corruption in the Company's system, raising legal awareness and legal culture of employees.
19. Preparation and distribution of educational materials aimed at conducting propaganda among employees of the Company and its structural organizations that corruption is an extremely negative vice for the development of society and the country.
20. Preparation of social video clips on anti-corruption themes and propaganda materials on the topics of corruption, honesty, correctness, respect for the law, the triumph of justice.
21. Organization of lectures, meetings and events by the Company and its structural organizations on the topic “Combating Corruption”.

Chapter 4. Timely detection of corruption offenses, eradication and elimination of possible causes and preconditions, ensuring the inevitability of responsibility for corruption offenses 

22. Opening a special page on the company's website that allows you to file complaints against employees, regularly analyze incoming complaints, and establish a mechanism for making informed suggestions based on their results.
23. Conduct research into the state of corruption in the Company's system, its aspects, scale, growth rates and trends, as well as the effectiveness of anti-corruption measures taken in the context of the Company and its structural organizations.
24. Organization of training courses to improve the qualifications of employees of the Company and its structural organizations, following the results of these courses to conduct anonymous surveys among students about the fight against corruption and the further development of the Company's activities.
25. Implementation of an electronic queue system when contacting the Company and its structural organizations.
26. Implementation of a procedure for rewarding persons who have reported corrupt behavior committed by officials of the Company and its structural organizations.
27. Preparation of proposals for further improvement of ethical rules when conducting studies in the Company's structural organizations.

 

Section 3: Expected Results of the Program

36. The following results are expected from the implementation of the anti-corruption Program in the “Dori-Darmon” JSC system:

- preventing corruption, conflicts of interest and other offenses in the Company's system;

- Further increase the responsibility of employees in terms of achieving the openness of organizations in the Company's system and meeting their objectives;

- Evaluating the performance of officers and other employees of the Company and its structural organizations on the basis of new criteria;

- Improving the ethics of employees of the Company and its structural organizations in professional and non-professional activities;

- Ensuring the effectiveness of measures to prevent corruption in the activities of the Company and its structural organizations.