M.Video–Eldorado Group strictly observes the applicable legislation and principles of business ethics. The Group’s Management is constantly working to reduce the risks of illegal and unethical behavior on the part of Russian market participants. Corresponding procedures of control are in operation both externally and internally.
Compliance with legislation and the priniples of business ethics for Group employees and business partners is regulated by the Code of Business Conduct of PJSC M.video, in addition to a number of special policies and procedures approved during its development. By adhering to them, each Group employee and business partner ensures that any risks that may arise from violations applicable to the respective relationships are mitigated. Employees from specialized Group divisions are involved in the implementation of procedures to minimize these risks.
In 2020, the Group approved an Anti-Corruption Policy and automated the corresponding procedures. The processes of declaring conflicts of interest, in addition to reporting alleged legal violations and infringements of business ethics, were also automated, thus making it possible to reduce the influence of human error and therefore to make these processes increasingly transparent and efficient. If information is received about an alleged legal violation or business ethics infringement, an internal investigation is carried out, and feedback is provided to all relevant parties. Retaliation against relevant parties is strictly prohibited.
The Group not only improves internal compliance control procedures but also exchanges best practices in this area.
The senior management of M.Video–Eldorado Group regards business ethics as one of the basic elements of corporate culture and considers it a guarantee of and essential to its long-term development.
In 2020, the Code of Business Conduct was approved for PJSC M.video and the Group as a whole. Previously, a similar document was valid only for MVM LLC (the key operating company of the Group). The Code contains fundamental principles of conduct that are consistent with the core values of the Company. Adherence to the Code is mandatory for every employee of the Group, regardless of their position. Business partners should also be guided by the rules that are provided in this document.
The Code makes it mandatory to comply with the highest standards of business ethics, even if they are not directly required by law or do not follow some of the practices generally accepted in the Russian market. This approach allows the Group to conduct its business honestly and openly, effectively minimizing the risks of abuse, and to take fully into consideration the interests of investors, business partners and the industry as a whole.
The principles established by the Code are detailed in other policies and procedures related to ethical business conduct (see below).
M.Video–Eldorado Group enacts and adheres to a principle of zero tolerance for any manifestation of corruption, be it commercial bribery, other forms of bribery or any other form of abuse of power. Any possibility of corruption is viewed by the management of the Company as a direct threat to its business reputation and economic operations.
In 2020, an Anti-Corruption Policy was approved, which sets out the requirements and procedures aimed at preventing corruption. This document is mandatory for every employee of the Group, regardless of their position. Business partners should also be guided by the rules provided in this document. The established practice of relations between market participants, the norms of applicable foreign law, as well as national or regional specifics are not grounds for ignoring the requirements provided for by the Policy.
According to the Code of Business Conduct of PJSC M.video, every employee is obliged to behave responsibly with regard to their personal interests and remember that all the resources and opportunities that they are endowed with by virtue of their position must be used exclusively in the interests of the Group.
MVM LLC (the main operating company of the Group) has a Conflict of Interest Regulation, which provides a mandatory procedure for the declaration and resolution of relevant situations. Each employee is required to report a real or perceived conflict of interest to the Ethics and Compliance Committee in writing. A risk-based conflict of interest investigation is conducted annually, involving any and all employees whose personal interests may affect the proper, objective and impartial performance of their duties.
Since 2020, the declaration process has been automated and takes place electronically. Protecting personal data is very important to the management of the Group; all information is sent to an independent server and is encrypted, thus preventing leaks and preserving anonymity.
Based on the results of the received declarations, the Ethics and Compliance Committee is able to take measures to minimize identified risks.
M.Video–Eldorado Group operates on a competitive basis, requiring all its employees and business partners to strictly comply with competition laws.
The Group has an Antimonopoly Compliance Policy , which sets forth requirements and procedures aimed at ensuring full compliance with competition laws and at mitigating the risks of violations. This document is mandatory for every employee of the Company, regardless of their position. Business partners should also be guided by the rules that are provided in this document. The system for reducing the risks of violating antimonopoly legislation is constantly updated based on any changes taking place in said legislation, law enforcement practices and the advice of the Federal Antimonopoly Service.
M.Video–Eldorado Group strives to maintain business relations exclusively with individuals who comply with the requirements of the law. Before starting partnerships, the Company checks each business partner so that the relationship with them is as mutually beneficial and transparent as possible. The due diligence checks are undertaken by the Counterparty Verification Policy.
The checks are carried out by employees from various departments, who also request documents from potential business partners to assess possible risks. After considering the received information, a joint decision is made to minimize possible risks. If a business partner is assigned a high level of risk, the issue of cooperation with them is subject to consideration by the Committee for the Selection and Approval of Counterparties.
The Group respects the confidentiality practices established by business partners concerning their documents and information. None of the information received from counterparties may be transferred to third parties.
M.Video–Eldorado Group is responsible for the collection, storage, processing and destruction of personal data. Regardless of who the subject of personal data is, be it a consumer, an employee or a business partner of the Group, any interactions or exchanges are carried out in strict accordance with the law. Requirements and procedures for said adherence to the law can be found in the Group’s Personal Data Processing Policy.
M.Video–Eldorado Group ensures that its employees comply with legislation pertaining to insider information in order to prevent its use to the detriment of the Company’s interests. The relevant issues are regulated by the Regulations on Insider Information.
M.Video–Eldorado Group will not stop here.
For 2021, it is planned to actively develop internal communications, conduct new training events, identify and minimize new compliance risks, and test existing control procedures.
