Antimonopoly Policy

Antitrust compliance is an internal system of a Сompany’s legal and organizational measures aimed at complying with the requirements of antitrust laws. The main task of antitrust compliance is to prevent possible violations of antitrust laws by a Сompany and its individual employees and to minimize antitrust risks.  

PJSC TransContainer has developed and is implementing Antitrust Compliance Policy of PJSC TransContainer, approved by the Board of Directors on December 27, 2021. The Policy defines:

• the goals, objectives and core principles of the antitrust compliance; 
• the structure of the antitrust compliance system; 
• the general requirements to procedures for identifying, assessing and preventing violations of antitrust laws, managing antitrust risks, conducting internal investigations; 
• the requirements to procedures for internal control over the operation of the antitrust compliance system. 

For the purposes of this Policy, the following internal regulatory documents in the field of antitrust compliance were approved by Order of PJSC TransContainer No. TsKP/2021-352 dated December 28, 2021: 

• Methodology for Identifying and Assessing Antitrust Risks in Activities of PJSC TransContainer 
• Methodology for Assessing Effectiveness of Organization and Operation of Antitrust Compliance System of PJSC TransContainer  
• Regulations on Procedure for Internal Investigations of Illegal Actions Related to Violation of Antitrust Laws 
• Policy of Conduct of PJSC TransContainer Employees on Compliance with Antitrust Laws 
• Regulations on Familiarization of PJSC TransContainer Employees with Regulatory Documents and Training in Antitrust Compliance Requirements. 

The compliance of the Policy and the specified internal regulatory documents of PJSC TransContainer with the antitrust laws requirements is confirmed by the Federal Antimonopoly Service of Russia.