We believe that anti-corruption awareness and training are a critical component of corruption prevention. All Nobel Energy Group employees are regularly trained on the rules of ethical conduct and encouraged to avoid illegal actions. The company regularly implements special training programs aimed at preventing corruption. Such trainings are provided both to our own employees and contractors. To properly understand the culture of bribery, new hires are familiarized with anti-bribery provisions during their foundation training program.
Special training programs aimed at preventing bribery are regularly updated to reflect changes in the law. In addition to the training programs, any employee may seek advice on anti-corruption policy, ethical conduct, confidentiality and similar issues from the officer responsible for the organization and compliance with ethical and regulatory requirements.
Nobel Energy pays special attention to the development of an effective method of reporting alleged or actual violations in order to prevent illegal actions, minimize the risk of corruption and fraud, and eliminate other forms of unlawful conduct. In particular, the company has implemented the Reporting procedure in accordance with best UK practices of corporate governance. The goal of this procedure is to furnish employees with a methodology for reporting actual or suspected cases of bribery, corruption or unlawful conduct and support them in implementing the “report a violation" and “growing concern" principles.