Anti-corruption

We identify and assess corruption risks in the Fund and in portfolio companies through anti-corruption monitoring and internal corruption-risk analysis (IACRA). The results are approved by the Chairman of the Management Board and serve as the basis for developing action plans to mitigate the identified threats.

To digitalize this process, we are developing a dedicated module within the E-Compliance system that provides systematic documentation of risks, transparency of data and their automatic integration into a single compliance-risk register.

In 2025, anti-corruption training covered 131,487 employees. Across the Group, 1,380 events were held to build an anti-corruption culture, with 120,613 participants, of whom 695 events involved senior management.

Screening covered both counterparties and job candidates. 17,711 counterparty compliance checks were performed, of which 1,780 were assigned a high risk level. 4,515 candidate checks were performed, with compliance risks identified for 640 individuals.

Conflicts of interest are declared upon hiring and on a regular basis. Since December 2024, this process has been automated in the E-Compliance system. In 2025, 873 cases of self-declared potential conflicts of interest were recorded, and a further 34 cases were identified.

Through the whistleblowing channels, in 2025 we received 737 external and 122 internal reports. We conducted 282 checks and internal investigations. In 72 cases, the facts stated in the appeals were confirmed or partially confirmed. The most frequently confirmed violations involved non-compliance with legislation and contractual obligations, internal documents, business ethics, and conflicts of interest.