The company's existing compliance system was based on documents developed at the level of a holding company registered in the European Union. Since the business processes of the Russian and European offices, as well as the requirements and recommendations of the authorized bodies to the compliance system presented in different jurisdictions and have some differences, the client applied to KIAP with a request to conduct a legal review of the current compliance system for its conformity with the requirements of Russian legislation.
After conducting an internal audit and receiving appropriate recommendations, KIAP employees were instructed to finalize the company’s existing regulations and policies related to compliance procedures.
In order for the client to receive "working" documents to ensure that the compliance system is efficiently integrated into all business processes of the Russian division and would be their reliable assistant, KIAP employees conducted numerous interviews and developed a policy of due conduct (compliance), a policy for the detection and prevention of emergency situations, as well as a policy on liability for violations of the Code of ethics and other compliance policies. All documents were prepared taking into account the requirements of Russian legislation, as well as Directive 2019/1937/EU “On the Protection of Whistleblowers”, ISO 37301:2021 - Compliance management systems and ISO 37002:2021 Whistleblowing management systems - Guidelines.
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