SUEK AG seeks to maintain high standards of corporate and business ethics.

We streamline these standards throughout the wide network of our offices to each employee working in SUEK AG (including all subsidiaries and branch offices) and we are committed to maintaining those standards as a matter of priority to us.

In order to support this, we have implemented the compliance system that includes a range of policies and guidelines.

Audit of Sanction Risks Management System

In 2019 the entire SUEK Group`s sanction risk management system and sanction compliance policies were audited and assessed by international US based company – Baker Botts L.L.P. who are one of the market leaders in international sanctions laws. In accordance with the Memorandum issued by that firm, SUEK Group’s policies were found to be thorough and well documented, and provide for an appropriate sanctions program that meets or, in some cases, exceeds regulator expectations and industry standards.

In order to maintain the level of efficiency of the system in consideration of constantly evolving sanctions law, SUEK AG plans to run the same audit on a regular basis.

Code of Conduct and Corporate Ethics

SUEK Group`s basic principles and standards of conduct and corporate ethics are also supported by SUEK AG and defined in this Code of Conduct and Corporate Ethics Global Code of Conduct and Corporate Ethics 2017 (the “Code”). This Code sets the basis for all our compliance policies, guidelines and procedures.

The Code is also the guidance that helps to perform our work in the best way, to interact successfully with each other and to make the right decisions in different situations. At the same time, it describes the principal ethical and social standards to be adhered to by all SUEK AG’s employees and officers. All our employees, regardless of the position and location, must follow and obey the Code. We expect that our business partners will share our vision and principles set out in the Code in their everyday activities.

The Compliance Committee

The Compliance Committee (“Committee”), in close interaction with the Compliance Officer, assists the Board of Directors and the Management of SUEK AG in its oversight of regulatory, compliance, legal matters and related risks that may affect the business of the Company. The Committee also monitors the effectiveness of the compliance risk management system inside the Company, including all its Compliance policies. The Committee conducts investigation and resolves on any significant instances of noncompliance or potential compliance violations or misconduct. The Committee reports directly to the Board of Directors. The Committee provides the Board of Directors with an annual report on the company’s performance and its own evaluation of the compliance risk management system; which includes a summary of all actions taken by the Committee and recommendations to the Board of Directors on any improvements to the compliance system.


All our employees receive ongoing training on prevention of bribery and corrupt payments, sanctions, anti-money laundering, anti-trust, confidential information and conflicts of interest.