Uralkali’s Anti-Corruption Policy applies to all employees, regardless of their position; it is also recommended that counterparties comply with the policy.

It is compulsory for new hires to study the Anti-Corruption Policy, and Company employees also receive regular training on how to fight corruption, both in person and remotely.

Every year, employees identified based on the annual reassessment of fraud and corruption risks sign statements of compliance with the Anti-Corruption Policy.

Monitoring Compliance with the Anti-Corruption Policy

Uralkali regularly monitors compliance with the requirements of the Company’s Anti-Corruption Policy and anti-corruption legislation.

The Company operates a 24-hour hotline available to all stakeholders to help monitor compliance with anti-corruption standards across all aspects of its activities.

Uralkali imposes strict requirements on its counterparties, their reliability and compliance with applicable laws and the anti-corruption standards adopted by the Company. Uralkali checks counterparty contracts to ensure these include anti-corruption clauses. Upon hiring, candidates are assessed for potential conflicts of interest.

Corruption risk management is part of the Company’s general risk management system. Corruption risks are included in the risk map and regularly reassessed to reveal potentially corruption-prone business processes.

The Company continuously improves its internal control system, with a particular focus on areas where there is high risk of fraud and corruption. All identified cases of corruption risks are recorded.

Uralkali’s Anti-Fraud and Corruption Programme covers all of its main business processes. This programme includes a plan of activities for the next year such as the provision of information, IT control, and field events at subsidiaries.

During the development of the Anti-Fraud and Corruption Programme, the Company’s business processes are analysed to evaluate their proneness to corruption.