Business Ethics and Compliance in Russia

Contents

• Foreword
• Acknowledgements
• Executive summary
• Introduction

1. Chapter 1: Doing business ethically in Russia
   1. Russian laws and regulations
      1. Existing anti-corruption legislation
      2. Impending legislation
      3. A selection of laws and regulations particularly affecting foreign entities
      4. Additional common regulatory issues
      5. Implementation of legislation
      6. Examples of cases where corruption presents real risks to business
   2. Russian business norms
      1. The cost of corruption in Russia
      2. Socially common practices
      3. Industry-specific examples of corrupt practices
      4. Corruption risks and threats when doing business in Russia
      5. Local expectation and perceptions of foreign multinational companies
   3. Trends in Russia's anti-corruption business culture
      1. Background
      2. Corporate practice and tolerance of corruption
      3. Long-standing customs
      4. Ownership transfer and the new oligarchs
2. Chapter 2: Russian engagement with international anti-corruption conventions and initiatives
   1. Support for international conventions
      1. OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions
      2. United Nations Convention against Corruption
      3. World Economic Forum Partnering Against Corruption Initiative (PACI)
      4. United Nations Global Compact: Principle 10
      5. The Council of Europe Criminal Law Convention on Corruption
      6. International Chamber of Commerce (ICC) Rules of Conduct to Combat Extortion and Bribery
      7. The Kimberley Process Certification Scheme (KPCS)
      8. The Extractive Industries Transparency Initiative (EITI)
   2. National regulations and global conventions
      1. How national legislation is influenced by the international community
      2. Industry-supported initiatives
      3. Current leadership's action against corruption
      4. Corporate compliance
      5. Trends
   3. Existing and emerging national and regional anti-corruption frameworks
      1. Government and public initiatives
      2. Key NGOs
      3. Regional initiatives
      4. Private-sector initiatives
3. Case studies
   1. Introduction to case studies
      1. Host-country-adapted codes of conduct
      2. Policy on gifts and client entertainment
      3. Training issues
      4. Due diligence
      5. Additional ways companies adapt in order to meet the host-country regulatory and cultural environment
   2. Case studies
      1. Compliance case study - KPMG
      2. Corruption case study - Hermitage Fund
      3. Tax Police short case study - Warren's Sausages
      4. Customs short case study
      5. Regional short case study
      6. Extortion short case study

• Conclusion
• Methodology
• Appendix 1: Internal ethics and compliance policy information - for select companies operating in Russia
• References