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On 14 July 2017, Decree No. 230 of the Russian Ministry of Emergency Situations "On Approval of the Regulations on Company Subdivisions (Employees) Authorized to Perform Civil Defense Tasks" dated 23 May 2017 (the Decree) entered into force.

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Under previous rules, the minimum required number of company employees responsible for civil defense matters depended not only on the civil defense category of the company, but also on whether the company is a company that would continue to operate in the event of war.

These requirements for the appointment of officers responsible for civil defense matters have been updated by the Decree.

Specifically, if the company has not been assigned a civil defense category, it is permitted to have only one officer responsible for civil defense matters working on a secondary basis (regardless of the number of employees at the company). In companies that are assigned a civil defense category, and in their branches and representative offices (depending on the number of employees), one or several employees must be appointed responsible for civil defense matters for whom this will be the primary place of work.

Whether a company is assigned a civil defense category depends on a number of factors, including the number of employees working during wartime, the company's output capacity (work, services) for state needs during wartime, etc. Therefore, the list of companies assigned a civil defense category may include commercial organizations whose goods and services could potentially be needed during wartime.

That said, at present, there is no public, consolidated list of organizations that have been assigned a civil defense category. According to the Moscow office of the Russian Ministry of Emergency Situations (the Ministry), in order to check whether a particular company has been assigned a civil defense category, an official inquiry should be made at the appropriate Ministry’ department at the company's location.

We remind you that violations in the area of civil defense lead to administrative liability according to the Section 2 of Article 20.7 of the Russian Code of Administrative Offenses. At the same time, proceeding from the latest position of the Ministry, the frequency of inspections from the Ministry will depend on the risk category of the company (with regard to risk-oriented approach). In particular, the first objectives of inspections will be companies that are assigned civil defense categories. Moreover, as the Ministry explains, its officers will be endeavoring to apply a business-oriented approach in case of offense disclosure, and will render a verbal warning or issue a reprimand if an administrative offense is committed for the first time (Letter No. 23-10-709 of the Russian Ministry of Emergency Situations dated 6 June 2017).

Implications for Employers

We recommend that our clients take these legislative changes into account, and ensure that officers responsible for civil defense matters are appointed in compliance with the Decree. We also recommend our clients to request the relevant local Ministry of Emergency Situations’ office on whether the company has been assigned a civil defense category.

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