Section I
The institution — FKU "Digital Culture", subordinated to the Ministry of Culture of Russia, complies with the principles of anti-corruption legislation and ethical business behavior. The anti-corruption policy is aimed at preventing corruption in the Institution, including the identification and subsequent elimination of the causes of corruption (prevention of corruption).
The legal basis for combating corruption is the Constitution of the Russian Federation, federal constitutional laws, generally recognized principles and norms of international law and international treaties of the Russian Federation, Federal laws, regulatory legal acts of the President of the Russian Federation, the Government of the Russian Federation and federal public authorities.
The anti-corruption policy is implemented within the framework of the implementation of Federal Law No. 273-FZ of December 25, 2008 "On Combating Corruption".
The Anti-Corruption policy declares the rejection by the Institution of corruption in any of its manifestations (abuse of official position, bribery, bribery, abuse of authority, commercial bribery or other illegal use by an employee of his official position contrary to the legitimate interests of the Institution, society and the state in order to obtain benefits in the form of money, valuables, other property or services of a property nature, other property rights for themselves or for third parties or illegal provision of such benefits to the specified person by other individuals), both in daily activities and in relationships with legal entities and individuals.
Employees of the Institution, as well as any third party acting on behalf and/or in the interests of the Institution, are prohibited from:
— offering or promising a bribe personally or through an intermediary (including when the bribe is transferred to another individual or legal entity at the direction of an official);
— receive personally or through an intermediary bribes in the form of money, securities, property and non-property services, as well as any financial or other benefit or advantage, if the receipt of such payments, benefits or advantages in itself constitutes improper performance of official or other duties stipulated by law or are a reward for improper performance of such duties;
— to mediate in bribery, commercial bribery, bribery of a person providing public services or providing/receiving illegal benefits;
— use official position and authority in order to obtain unlawful benefits for yourself or others, including using any property for personal interests.
Employees of the Institution, as well as any third party acting on behalf and/or in the interests of the Institution in connection with the prevention and combating of corruption in their activities are obliged to:
— not commit corruption offenses related to the activities of the Institution;
— refrain from behavior that can be regarded as a willingness to commit a corruption offense related to the activities of the Institution;
— inform about cases of incitement to commit a corruption offense related to the activities of the Institution;
— inform about cases of corruption or corruption-related offenses committed by other employees of the Institution or other persons;
— immediately inform the management about the emergence of personal interest, which leads or may lead to a conflict of interests.
The provisions of this Anti—Corruption Policy are based on the principles of anti-corruption: - recognition, provision and protection of fundamental human and civil rights and freedoms;
— legality;
— publicity and openness of activities;
— the inevitability of responsibility for the commission of corruption offenses;
— comprehensive use of political, organizational, information and propaganda, socio-economic, legal, special and other measures;
— priority application of measures to prevent corruption;
— cooperation with civil society institutions, law enforcement agencies, international organizations and individuals.
Section II
The Institution adheres to the state systematic approach to solving corruption problems, including anti-corruption education, elimination of the causes of corruption offenses, creation of specialized bodies in the management system of the Institution responsible for the implementation of anti-corruption policy, taking measures to prevent and resolve conflicts of interest.
The anti—corruption policy defines measures aimed at the prevention and prevention of corruption, as well as principles and mechanisms for their implementation in order to:
— create an effective mechanism that prevents corrupt actions and minimize the risks of involving its employees in corrupt activities;
— education of legal and civil consciousness of employees by forming a negative attitude to corruption and illegal redistribution of income and other benefits between employees, as well as education of skills of anti-corruption behavior of employees;
— minimization of property and reputational damage by suppressing corrupt actions and punishing them with the use of public, administrative and law enforcement procedures.
To achieve its goals, the Institution solves the following tasks:
— increasing the openness and transparency of the Institution's activities;
— creation of a methodological basis for the development of internal documents regulating activities in the field of prevention and combating corruption, based on the analysis of the causes and conditions of corruption risks in the process of activity;
— involvement of each employee in the implementation of measures to prevent corruption;
— organization of effective monitoring of corruption factors and ensuring the effectiveness of anti-corruption policy within the framework of the anti-corruption control and monitoring system of the Ministry of Culture of Russia.
Consistent and systematic implementation of the Anti-Corruption Policy is aimed at reducing corruption risks.
The provisions of this Anti-Corruption Policy apply to all employees, regardless of their position.
The key principles of the implementation of the Anti-Corruption Policy are:
1) rejection of corruption in any forms and manifestations. The institution promotes the education of legal and civil consciousness of employees by forming a negative attitude to corruption manifestations. Executives act as an example of proper ethical behavior;
2) effectiveness of anti-corruption measures. Creation of an effective anti-corruption system, as well as its systematic improvement;
3) ongoing monitoring and follow-up. Creation of an effective system of control and monitoring of corruption factors and risks;
4) verification of the reliability of counterparties. The institution checks contractors within the framework of procurement activities in order to reduce corruption risks and prevent the involvement of employees, regardless of their position, in corruption activities, as well as in order to ensure fair competition;
5) openness of information. Ensuring accessibility for citizens, legal entities, mass media and civil society institutions to information about their activities, which, in accordance with the current legislation of the Russian Federation, are not restricted access information.
As part of the implementation of the principle of openness of information, the Institution creates a subsection on anti-corruption issues on its official website, which includes: documents on anti-corruption issues, information communication channels that guarantee the anonymity of the applicant (telephone, e-mail, online service, postal address for mail marked "Anti-corruption").
The anti-corruption policy in the Institution is implemented by the head, the Commission for Combating Corruption and Conflict of Interest Resolution and the unit (person) responsible for the prevention of corruption and other offenses.
The facts of obstruction of the activities of the unit (person) responsible for the prevention of corruption and other offenses, and non-fulfillment by employees of the requirements imposed by the unit (person) responsible for the prevention of corruption and other offenses, within the established rights and obligations, are immediately brought to the attention of the head of the Institution.
Section III
The institution applies the following methods of prevention and combating corruption:
— legislative;
— personnel;
— monitoring and control;
— spiritual and moral.
As an implementation of the legislative method, the Institution and its employees comply with restrictions and prohibitions, perform duties established by the legislation of the Russian Federation, including those related to the prevention and settlement of conflicts of interest and ensuring disclosure of information (in case of personal interest), and also conducts anti-corruption expertise of ongoing projects and concluded contracts, carries out legal education of employees.
Within the framework of the personnel method, the Institution conducts a balanced personnel policy aimed at minimizing corruption risks associated with hiring and promotion, as well as appointment to positions whose replacement is associated with an increased corruption risk.
The institution applies the method of monitoring and controlling corruption risks:
— identifies and analyzes and evaluates (in terms of scale, sources and probability of threats) corruption risks inherent in business processes in all areas of its financial and economic activities, as well as assessing potential damage from potential risks;
— organizes and conducts on an ongoing basis monitoring and control of corruption risks inherent in the Institution;
— if necessary, on the basis of ongoing monitoring, carries out corrective changes in its anti-corruption system and/or initiates prosecution in accordance with the legislation of the Russian Federation on the fact of identified corruption offenses.
As an implementation of the spiritual and moral method, the management of the Institution forms an attitude of intolerance towards all forms of corruption in the team, encourages employees to work effectively on the principles of cohesion, openness, integrity and responsibility.
Non-compliance by employees with the norms and rules of business ethics may entail the application of disciplinary penalties to the violator, as well as the initiation of administrative, civil and criminal liability measures on behalf of the Institution in accordance with the procedure provided for by the current legislation of the Russian Federation.
The units (persons) responsible for the prevention of corruption and other offenses in the Institution conduct an audit of transactions, the coordination of which with the Ministry of Culture of the Russian Federation in accordance with the legislation of the Russian Federation is not required for the presence of a corruption component.
Transactions and other operations containing the highest corruption risks and subject to mandatory control include:
— procurement of material and technical resources;
— repair and maintenance of material and technical resources;
— transport service;
— construction, repair and reconstruction of buildings, structures, premises;
— reconstruction of buildings, structures, premises and art objects;
— execution (subcontracting) of research, development, design and survey and construction and installation works;
— implementation of consulting, including educational services;
— provision of sponsorship;
— iring and promotion of senior staff.
The results of the inspections are reported to the Anti-Corruption and Conflict of Interest Resolution Commission and the head.
If the fact of damage to an Institution, including state property under its jurisdiction, is established through the fault of an employee, the Institution has the right to apply to the court for compensation for damage caused as a result of the above actions (inaction).
The institution, no later than seven days from the moment of suspicion or detection of actions (inaction) of employees who have signs of violation of the legislation of the Russian Federation on combating corruption, sends relevant materials to law enforcement agencies within their competence to implement measures established by law in order to assess the legality of actions (inaction) of the relevant persons.
The implementation of the Anti-Corruption Policy of the Institution subordinate to the Ministry of Culture of the Russian Federation promotes the introduction of anti-corruption standards and establishes the order of the anti-corruption system in the Institution, effective mechanisms that prevent corruption actions, minimizes the risks of involving the Institution and its employees in corruption activities by forming a negative attitude to corruption manifestations, involving each employee in the implementation of measures to prevent corruption.
You can also read the documents
Regulation on the Commission for Combating Corruption and Resolving Conflicts of Interest of the Federal State Institution "Digital Culture" (RU)
Code of Ethics and Official Conduct of the Federal State Institution "Digital Culture" (RU)
Regulation on the structural unit (person) responsible for the prevention of corruption and other offenses in the Federal State Institution "Digital Culture" (RU).