|
No. |
Necessary actions |
Performed actions |
Confirmation |
|
I. Creation of mechanisms and legal framework to prevent violations of competition law requirements |
|||
|
1.1. |
Development and approval of internal regulations defining the procedure for implementing the antimonopoly compliance system. | On the part of CRPC, the Regulations on the implementation and operating procedure of antimonopoly compliance were approved by the Appendix No. 1 to Order No. 198 dated 29.12.2022. | |
|
1.2. |
Development and approval for one year of a “road map” to reduce the risks of violations of antimonopoly legislation. | On the part of CRPC, the Road Map for 2023 was approved by the Appendix No. 2 to Order No. 198 dated 29.12.2022. | |
|
1.3. |
Establishment of means of communication intended for reporting of actions that lead or may lead to restriction of competition, as well as discrimination of the rights and legitimate interests of consumers in the conditions of competition or natural monopoly. | On the official website in the “Contacts” section there is the telephone number of the Call Center for cardholders (71 200 28 28), as well as the separate number and email address of the “Hotline” and the form for requests via the website to receive requests from third parties by facts of fraud, corruption and violation of antimonopoly legislation (+998 71 203 43 34). | https://uzcard.uz/hotline-uzcard
https://www.uzcard.uz/ru/contacts
|
|
1.4. |
High-quality and timely provision of the report on compliance with antimonopoly legislation and posting on the official website. | This report will be published on the official website after approval by the Committee for the Development of Competition and Consumer Protection. | |
|
II. Implementation of measures to identify, assess and prevent risks of violating the requirements of antimonopoly legislation. |
|||
|
2.1. |
The number and volume of cases of violations identified as a result of studying the materials related to the activity (including checking the internal documents aimed at identifying the rules limiting competition or the rights and interests of consumers). | In 2023, from the side of CRPC:
– neither monopolistically high nor monopolistically low prices are set; – there was no abuse of the dominant position or superior bargaining power; – there were no attempts to conclude anti-competitive agreements or coordinated actions with other competing business entities; – there were no actions that could be interpreted as unfair competition. |
|
|
2.2. |
Actions taken to eliminate identified violations and shortcomings and prevent their occurrence in the future. | In 2023, CRPC did not violate the Law of the Republic of Uzbekistan “On Competition”. | |
|
2.3. |
The number and direction of cases of violation of the law requirements prevented in the course of activities. | In 2023, 5 potential violations of the Competition Law were identified and prevented in the process of purchasing goods and services.
– 1 case of unreasonable restriction of tender. – 1 case of unjustified reduction of ratings for tenderers. – 1 case of presentation of unreasonable requirements for the qualification of tenderers. – 1 case of unjustified reduction of ratings for tenderers. – 1 case of apparent conflict of interest. |
The process of identifying and eliminating these factors is recorded in internal communications via corporate email. |
|
2.4. |
Identified factors that may cause restrictions on competition in the activities of the organization, and developed proposals for their elimination. | The developed risk matrix assesses the likelihood of violating various provisions of the Competition Law. One of the main shortcomings was the lack of regulated procedures for managing conflicts of interest, checking counterparties, and agreeing on new tariffs. In this regard, the Internal Control, Compliance and Risk Service of CRPC has developed drafts of these regulations | Appendix No. 1 List of developed local regulatory documents to ensure antimonopoly compliance |
|
2.5. |
Studying draft internal regulatory documents that are subject to adoption, eliminating norms in them that may entail violations of competition law requirements, as well as carrying out appropriate work to bring them into compliance with legal requirements | During the analysis of draft internal regulatory documents on the coordination of marketing campaigns and the approval of contracts, it was revealed that control and responsibility for compliance with the provisions of the Law “On Competition” were not taken into account. Appendix No. 1 contains draft internal regulatory documents, after making the necessary changes at the initiative of the person responsible for antitrust compliance to ensure compliance. | Appendix No. 1 List of developed local regulatory documents to ensure antimonopoly compliance |
|
2.6. |
Developed proposals for making appropriate changes to the company’s documents and their implementation in connection with changes made to competition legislation. | After approval of the new version of the Law “On Competition”, a check was carried out on the relevant internal regulations of CRPC; based on the results of this check, no contradictions were identified with the new version of the Law “On Competition”. However, the new provisions of this law will be taken into account in the developed procedure for checking counterparties and in the new edition of the procurement procedure in 2024. | |
|
2.7. |
Speeches in the mass media and social media about the activities of the antimonopoly compliance system. | In 2023, the publication was made on the official website of CRPC, containing the address from the General Director of the Company and the importance of antitrust compliance. | https://uzcard.uz/ru/news/post/obrashchenie-generalnogo-direktora |
|
III. Activities of government bodies and heads of business entities to prevent violations of competition law requirements |
|||
|
3.1. |
Appointment of an authorized person (subdivision), provision of the necessary resources and other material and technical base in order to implement the antimonopoly compliance system in the organization and ensure its functioning | By the Order No. 46 dated 15.05.2023, CRPC appointed a person responsible for the implementation of antimonopoly compliance at CRPC – the Director of Internal Control, Compliance and Risks M. M. Ishonov. | |
|
3.2. |
Consideration by the heads of the organization of the issue of ensuring compliance of the organization’s activities with the requirements of competition legislation at board meetings and other meetings. | At CRPC, the highest executive body is the General Director. The General Director of CRPC approved the regulations on the introduction and operating procedure of antimonopoly compliance. In addition, the General Director holds regular meetings with the person responsible for antitrust compliance at CRPC to discuss current issues and provide advice on protecting consumer rights. | These meetings in 2023 were not recorded as there was no need for it. In 2024, these meetings will be recorded for the purposes of the annual antitrust compliance report. |
|
IV. Awareness of employees about internal procedures to prevent violations of competition law requirements and the implementation of measures to improve their knowledge and skills in this area. |
|||
|
4.1. |
Increased employee knowledge and skills about competition law in the reporting year | At CRPC, training was conducted by the Director of Internal Control, Compliance and Risks for company employees to improve knowledge and skills in the field of current competition legislation. Representatives of the purchasing, marketing, commerce, and information security departments took part in this training. | Appendix No. 2 Photos from the antimonopoly compliance training |
|
4.2. |
Availability of special educational programs and manuals for training and retraining of the organization’s employees to comply with the requirements of competition law. | The Internal Control, Compliance and Risk Service has developed training materials that help employees of CRPC understand the essence of antimonopoly compliance and the basic requirements applicable to CRPC. | Appendix No. 3 Training materials on antitrust compliance |
General Director Zakirov О. А.
Prepared by:
Director for Internal Control, Compliance and Risks Ishonov M. M.