Our approach to management

Magnit maintains high legal, ethical and moral standards as part of our business activities and cooperation with business partners. These standards are set out in Magnit’s Business Ethics Code, which is grounded in best Russian and international business conduct practices, corporate governance and relationships with employees and other stakeholders.

Healthy human relations are at the core of every company, especially in the retail industry. The actions and decisions of any of our employees build and strengthen the Company’s overall reputation. We seek to ensure that all our hires make honest and appropriate decisions based on the principles set out in the Code and follow guidance that will enable us to meet the highest standards of business ethics.

Our zero-tolerance approach to corruption in all its forms provides the basis for the Anti-Bribery and Corruption Policy, which underpins our corruption risk management system and our corruption prevention tools. Magnit’s managers and employees should avoid being affected by any influences, interests, or relations that may harm the Company’s business or facilitate any corrupt practices.

All new employees are required to attend courses on business ethics, information security and Anti-Bribery and Corruption Policy, with refresher courses provided every three years.

Principle	Our responsibility
Zero tolerance towards corruption	Our Company is committed to zero tolerance of corruption in all its forms, both on the corporate level and in stakeholder relations.
Liability for corrupt practices	We make every effort to promptly and indivertibly prevent any corrupt practices in accordance with the Company’s by-laws.
Senior management leadership by example	Members of the Board of Directors, the Chief Executive Officer and other senior officers of the Company take a zero-tolerance approach to corruption, establish and observe high ethical standards of business conduct and set an example for all Magnit employees.
Corruption risk identification and assessment	We identify and regularly assess corruption risks relevant to the Company’s operations, taking into account its strategic and investment development plans.
Control procedures	We have implemented control procedures to minimise corruption risks, including, but not limited to, checks of counterparties and addition of an anti-corruption clause to contractor agreements. We regularly assess the effectiveness of our anti-corruption control procedures and take steps to improve them.
Counterparty checks	To minimise reputational, financial and operating risks arising from relations with untrustworthy counterparties, we conduct thorough counterparty checks. We analyse information from open sources about the extent to which the counterparty adheres to ethical business principles and any anti-corruption practices it has in place, along with its willingness to comply with our principles, and include anti-corruption provisions in agreements, as well as cooperate to ensure ethical business conduct and minimise corruption risks.
Communication and training	Our Anti-Bribery and Corruption Policy is publicly available on the Company’s website. We communicate anti-corruption principles and requirements to our employees, contractors, suppliers and other stakeholders. All our new hires go through mandatory anti-corruption training.
Monitoring and control	We regularly assess compliance with anti-corruption procedures and communicate the results to the senior management and shareholders.

All Company employees receive anti-corruption training after joining Magnit and are subject to control tests to check their acquired knowledge. In 2022, a total of 3,818 employees completed anti-corruption training.