3 – Regular violations of rights
The ITUC Global Rights Index

Russian Federation

The ITUC affiliates in the Russian Federation are the Confederation of Labour of Russia (KTR) and the Federation of Independent Trade Unions of Russia (FNPR).

Russian Federation ratified Convention No. 87 on Freedom of Association and Protection of the Right to Organise (1948) in 1956 and Convention No. 98 on the Right to Organise and Collective Bargaining (1949) in 1956.

In practice

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Unions are denied access to workers at JSC Northern Shipping Company31-12-2019

The Confederation of Labour of Russia (KTR) denounces the abusive practices of the management of the Arkhangelsk Sea Commercial Port, which prevent the union from having access to seafarers and crews.

For two years, the management of this port has prevented unions from even talking to workers in the port, despite the direct regulation in the Federal Law of 12 January 1996 No. 10-ФЗ “On Trade Unions, Their Rights and Guarantees of Activity” and the International Ship and Port Facility Security Code (ISPS Code), which respectively contain rules on the right of trade union representatives to free access to organisations and workplaces to carry out their statutory activities and the requirement that port facility security plans include simplified access procedures for representatives of organisations dealing with consumer services and working conditions for seafarers.

In 2018, KTR representatives were denied access to the port area on the absurd ground that there was no collective agreement with the trade union.

In 2019, despite KTR’s appeals to the General Prosecutor’s Office and the Ministry of Transport, the port management again refused to grant one-year passes to KTR representatives, offering instead to issue a single application for every visit. Such arrangement deprives union representatives from having unfettered access to workers who usually only stay for a short period in the port.

Strict laws prevent workers from striking31-12-2019

The Confederation of Labour of Russia reports that the right to strike is largely limited by domestic law, which prescribes a lengthy and arduous bureaucratic process to request permission to strike while courts also have a significant margin of appreciation when deciding on the legality of strike actions. As a result, the number of lawfully held strikes in the form prescribed by law was zero in 2018 and two in 2019 throughout the Russian Federation.

Anti-union discrimination in major companies31-12-2019

According to the FNPR, the retail chain Magnit is notorious for its anti-union stance. In 2019, for example, the managers of regional subsidiaries in Murmansk, Omsk and Krasnodar fired the leaders (the chairs or deputy chairs) of the enterprise-level trade union committees. Leaders dismissed include Denis Schafen, Vasily Ivanov and Konstantin Ivanov. The trade unionists brought the matter to court. While Vasily Ivanov (Omsk) was reinstated by court order, Konstantin Ivanov and Denis Schafen were still waiting for the decision by the end of 2019. Along with constant attempts to get rid of trade union leaders, the retail chain continues to avoid collective bargaining with representative unions.

Similarly, Nestlé has implemented large-scale anti-union measures, summoning over 300 employees of several regional subsidiaries on 14 May 2019 to coerce them into resigning from their union. According to the employees, they were prevented from leaving before they had signed a letter confirming that they withdrew from the company union.

Nestlé also massively fired workers based on their union membership. Such practices have had a disastrous effect on trade union membership in the company with a 70 per cent decrease in trade union membership. The Agro-Industrial Workers’ Union of the Russian Federation (an affiliate of the FNPR) organised a solidarity campaign. By the end of year, the matter was not settled.

Finally, Aleksandr Sorokoletov, deputy head of the enterprise-level trade union committee at the NAO “Center-Omega” (one of the biggest real estate developers in Krasnodar region), was dismissed in April 2019. According to FNPR, this measure was an obvious anti-union attack, as the company had repeatedly tried to destroy the company union since 2016. At the end of the year, Aleksandr Sorokoletov was reinstated following a decision of the court.

Legal provisions render assemblies and protests difficult31-12-2019

In the Russian Federation, the legislation establishes a pre-authorisation procedure for the organisation of public events and allows public authorities to deny permission to trade unions and associations without requiring them to provide grounds or reasons for this refusal.

Such laws affect the capacity of trade unions to organise protests and assemblies in public spaces. In 2019, two applications for rallies and pickets in support of political prisoners from the University Solidarity union were rejected. At the end of 2019, the prefecture of the Central Administrative District of Moscow did not give permission to the Novoprof union to hold a picket in the city centre, opposite the café, regarding migrant workers not having received their salaries. In other instances, state authorities proposed moving the picket to a place far away from the city centre where the visibility and impact of the protest action would be insignificant. Furthermore, in 2019 all public events organised by the Teachers’ Trade Union were prohibited.

Source: Confederation of Labour of Russia questionnaire

The Confederation of Labour of Russia reports that following the raid of a SUR Northern regional organisation in 2017 by the armed transport police forces, the Prosecutor’s Office decided after two years of delays to not initiate a criminal investigation into these facts.

The 2017 raid was an attempt to accuse the head of the organisation of abuse of authority and misappropriation of funds of the organisation.

Union banners banned in Arkhangelsk Region31-12-2019

The regional parliament of Arkhangelsk Region adopted a law which prohibits using banners with social and economic slogans closer than 50 metres to any cultural, social, sport, religious, etc., facilities. The law virtually prevents anyone from using banners with slogans in the central parts of the cities; therefore, it hinders any protest actions organised by trade unions.

Furthermore, the police confiscated 16 trade union banners in Syktyvkar (the capital of the Komi Republic) during May Day demonstrations. The slogans focused on local social and ecological issues. The trade union has lodged a complaint with the attorney’s office.

Withholding of dues16-12-2018

The Federation of Independent Trade Unions of Russia (FNPR) reported several incidents where the employer abusively withheld union dues. For example, in 2018, the protracted conflict between the management of the LLC Yurginsky Machine Engineering Plant and the enterprise-level union continued, and the management repeatedly resorted to withholding union dues, despite numerous court orders against this practice. Each time, the management transferred some arrears to the union following the court order, only to resume this anti-union practice later on. Pskovpassagiravtotrans, a company providing bus transportation services in Pskov, also withheld union dues for several months in 2018. By the end of the year, the trade union had appealed to the regional attorney office, asking for investigation.

European Court of Human Rights re-affirms right to strike in key decision23-11-2018

Anatoly Ognevenko, a member of the Russian locomotive railway union RPLBZh, was dismissed from his job in Moscow on April 28 2008 after he participated in a one-day strike over wages. While the Russian courts did not challenge the legality of the strike, they nevertheless refused to declare his dismissal unlawful. The case, which was opened at the ECHR in 2009, was based on an analysis of formal compliance with the relevant Russian laws. It concluded with the finding that the dismissal was a disproportionate restriction on Ognevenko’s right to freedom of association.
The Court once again confirmed that the right to strike falls under the protection of Article 11 of the European Convention on Human Rights as an important aspect of the right to freedom of association by basing itself on the ILO supervisory bodies, which consider the right to strike as an indispensable corollary of the freedom of association.
The Court also noted that the ILO regularly criticised Russian legislation banning railway workers’ right to strike. It declared that there is no reason to reject the existing international approach to the definition of an essential service and to consider the railway transport as such.
“The right to strike is fundamental, and as with other basic workers’ rights, it is under attack in many parts of the world. This decision from the ECHR re-affirms the right to strike, based in international law with the jurisdiction of the International Labour Organization. We welcome the decision, in the full knowledge that the rule of law means that the right to strike must be respected,” said Sharan Burrow, ITUC General Secretary.

Anti-union dismissals11-11-2018

According to the Federation of Independent Trade Unions of Russia (FNPR), a number of trade union leaders have fallen victim to discriminatory measures in 2018. Olga Grusha, deputy chair of the enterprise-level union of the All-Russian Life-Support Workers’ Union (ALSWU – an affiliate of the FNPR) in Primteploenergo, a state-owned electricity and water supplier – was summarily dismissed in January 2018 during a protracted conflict between an enterprise and the union. She challenged her dismissal in court with the support of the regional union and in March 2018, Olga Grusha was reinstated by court order. A similar case was recorded in the Tomsk Region, where trade union members working for funeral services were fired in January 2018 and successfully petitioned the court for reinstatement two months later.
In July 2018, the court reinstated a member of the regional organisation of the All Russian Union of Automobile Transport and Road Workers (a FNPR affiliate) in Sverdlovsk region; he had been denied access to his workplace by his employer, the transport company “Profile”. Finally, in November 2018, the court reinstated Raisa Zaugolnikova, the deputy chair of the enterprise-level union at Teploenergo Comfort Ltd (Perm Region). Zaugoinikova had faced anti-union pressure immediately after the creation of the union in early 2018. She received several reprimands and was then fired. However, despite the court order of reinstatement, the employer continued their pressure on Zaugoinikova and as a result, she was constrained to resign soon after her reintegration, together with a majority of the members of the enterprise-level union.

Protests curbed during the FIFA World Cup31-07-2018

According to the Federation of Independent Trade Unions of Russia (FNPR), in 2018 authorities have often misused the Federal Law no. 54 of 2004 on demonstrations to ban or disrupt union meetings and protests. Pursuant to section 8 of the Law, the authorities may reject the venue chosen by the organisers.
In February 2018, in Chelyabinsk, the regional organisation of the All-Russian Life-Support Workers’ Union (ALSWU – an affiliate of the FNPR) – was effectively prevented from holding a demonstration to protest against the reform of the municipal public utilities. The authorities rejected all the appropriate places for the demonstration, chosen by the trade union.
In July 2018, trade unions organising protests against the increase of the retirement age faced opposition by regional authorities (in Vladimir, in Petropavlovsk-Kamchatsky, in Kurgan, in Ufa, etc.) who were trying to reduce the visibility of trade union meetings by rejecting proposed venues and having trade unions hold their meeting in some remote areas. In some cases, the authorities pretexted security measures due to the 2018 FIFA World Cup, while in fact they were restricting assembly and demonstration rights even in cities where no FIFA events where held, like in Vladimir.

Dissolution of ITUWA overruled22-05-2018

On 22 May 2018, the Supreme Court of Russia overruled the verdict of the Saint Petersburg city court, which on 10 January ruled to liquidate the Interregional Trade Union Workers’ Association (ITUWA), an IndustriALL affiliate.
Prosecutors argued that there were irreparable violations which led to the dissolution: Firstly, the union statutes do not specify which constituent regions of the Russian Federation are covered by the organisation, which they claimed is in violation of its legal status as an interregional public organisation. Further, the prosecutor’s office claimed that members of the union should be united by occupation, and ITUWA includes temporarily unemployed people, retired workers and students as well as workers. According to the union, this is not contrary to existing legislation. Finally, the prosecutors argued that ITUWA violated the law on foreign agents in connection with political activities, such as the publication of materials against tax increases for truckers, and collecting signatures online in support of modifications to the Labour Code, and assistance from abroad.
During the hearing, the union reported that the prosecutor’s office of Saint Petersburg had never sent the list of violations with possible remedies. The prosecutor’s office insisted on the most extreme measure, demanding ITUWA’s dissolution, instead of the suspension of the activities of the union. The union pointed out that it was not subject to the legislation on foreign agents, that the publication of materials on socially significant issues was its right, and funding from IndustriALL was targeted and carried out within the normal practice of cooperation with the international trade union movement. ITUWA has been affiliated to IndustriALL since 2007.
The prosecutor’s office tried to convince the Supreme Court judges that the liquidation of ITUWA was not a violation of workers’ rights, but would aid the creation of a new organisation that would meet all the legal requirements. The judges did not credit these arguments and overruled the earlier decision.

Russian Police Shut Down Factory Workers’ Online Community for Planning a Protest14-11-2016

Workers at Sedin Machine-Tool Plant in Krasnodar were organising a protest through a community set up through the social network Vkontakte.

However, on 12 November 2016, they saw their access to the platform denied and the community blocked in application of an order issued by the General Prosecutor on 11 November. The social network Vkontakte publicly stated that it does not know the reasons behind the ban of the online community by Russian authorities and that it has officially asked for a formal explanation about what occurred.

According to the declarations made by a spokesperson of Roskomnadzor - the Russian Federal Agency for Censorship - the trigger that initiated the censorship was a post in the community, issued on 9 November, calling for a “people’s gathering” which, according to the Russian authorities, is considered to be an “unauthorised mass event”. In spring, representatives of the ruling party promised workers that their wage arrears would be promptly paid and that new investors would be found to revitalise the region’s manufacturing industry. However, more than seven months later workers’ overdue salaries were not paid and many of them were forced to take unpaid leave and to accept a renegotiation (in reality, a worsening) of their labour contracts.

Russian authorities stopped a legitimate workers’ activity and, in response, workers have launched a new online community to replace the one banned by the government and are currently trying to organise a new protest.

Strike on the 2018 World Cup Stadium in Nizhniy Novgorod16-03-2016

Workers of the 2018 World Cup Stadium in Nizhiniy Novgorod went on strike denouncing unpaid work and the absence of employment contracts. Their employer, a Turkish subcontracting company, shifted all responsibilities to the main contractor. The latter refuted all accusations saying that payments were always made on time. During the World Cup preparatory works there were two cases of wage arrears regarding the stadiums, fatal accidents at the construction of the stadium in St. Petersburg and an occupational health and safety accident at the stadium in Volgograd. All these incidents led to huge mistrust among workers in relation to the organisation behind the World Cup. In this respect, Ambet Yuson, General Secretary of the Building and Wood Workers International (BWI), stated that trade unions have been excluded from the preparations for the World Cup with no opportunity to ensure protection of labour rights (on-time payment, decent conditions of work, employment contracts, etc.).

Kachkanar Mining and Ore-Processing Plant does not respect collective agreements excluding trade union from due consultation03-03-2016

The Miners’ and Metallurgical Workers’ Union of Russia (MMWU), through its local leader Anatoly Pyankov, stated that the Kachkanar Mining and Ore-Processing Plant (EVRAZ KGOK) failed to respect the collective agreement provisions. EVRAZ KGOK management completely disrespected the collective agreement, which provided for consultations during all stages of corporate restructuring, by unilaterally reducing the headcount and payrolls. Despite the fact the plant’s production output and profit are rising, management claimed that it was necessary to cut staff costs. Some 150 workers quit their jobs after compensation was offered on an individual-negotiation basis, while some others were forced to take unpaid leave. Workers, had no choice but to accept the draconian conditions imposed by the enterprise which is the major employer in Kachkanar.

Criminal prosecution of trade union activist:16-12-2014

On 15 December 2014, Nakhodka city court handed down a guilty verdict against Leonid Tikhonov, chairman of the Russian Trade Union of Dockers of East Port. He was sentenced to imprisonment in a penal colony for 3 years and 6 months for embezzling union funds. The Dockers’ Union of Russia believes that the allegations against Tikhonov are false and that he is being victimised for his trade union activities.

Metalworkers face union busting:17-10-2014

Union representatives at Turbodetal tried to negotiate a collective agreement with the management concerning the problem of underpaid workers holding more than one position and the increase in the costof- living. Tired of fruitless talks, workers called for a general assembly on 17 October 2014 in which they demanded to be compensated for working more than one job and better pay to cover inflation. As a consequence the factory management set out to bust the union. According to the union committee, factory supervisors received instructions on how to force workers to withdraw from their trade union. The supervisors and team leaders themselves were threatened with having their bonuses cut or stopped if they failed to persuade workers to leave the union. As a result of the union busting, around 200 workers withdrew from the union.

Constitutional Court rules in favour of union24-10-2013

On 24 October 2013, the Constitutional Court ruled in favour of the All-Russian Oil, Gas, and Construction Workers’ Union and the All-Russian Public Institutions and Public Services Workers’ Union regarding their right to freedom of choice of trade union structure. In 2010, trade unions introduced a number of amendments to their statutes ensuring their right to create inter-regional, territorial (municipal, inter-municipal, and city), amalgamated, sector-based, district and other trade union organisations. However, the Prosecutor’s Office decided that this was not in conformity with the Federal Law “On Trade Unions, Their Rights and Guarantees of their Activity”. The Constitutional Court overruled this decision by declaring that Article 3 of the Federal Law “On Trade Unions, Their Rights and Guarantees of their Activity” was unconstitutional.

Trade unionists arrested20-10-2013

On 18 and 20 October, Alexei Shliapnikov, Valery Pimoshenko and Sergei Knyshov, leaders and activists of the Sheremetevo Trade Union of Airline Pilots (ShPLS), were arrested by the police and subjected to criminal investigation for an alleged attempt to extort a large sum of money from JSC Aeroflot. According to the Russian Confederation of Labour (KTR), these accusations were in retaliation to the loss of the court case against the union over unpaid wages for night work and hazardous work in 2011/2012. The company has been engaged in a campaign against the union. For years, ShPLS has been fighting for the right to sign its own collective bargaining agreement with the employer to reflect unique aspects of airline pilots’ work – including work and rest schedule, leave, planning, insurance, and health check-ups. Aeroflot management refused to participate in any official negotiations with the ShPLS. It even launched a media campaign against the union, the main objective of which was to block collective bargaining negotiations as well as to avoid the court ordering payments to pilots.

Anti-union discrimination16-08-2013

Bashneft, one of the largest oil companies in Russia, threatened workers who intended to join unions with dismissal. This led to hundreds of workers leaving the Russian Chemical and Allied Workers’ Union (RCWU).

Mr. Morozov and Mr. Kolegov, two trade union leaders employed at Heineken Joint Breweries were dismissed for protesting against contract and agency labour. The Prosecutor’s Office deemed their dismissal unlawful and ordered management to reinstate them.

Refusal to bargain in good faith16-08-2013

The Benteler Company refused to bargain with the ITUA when the union refused to sign a non-disclosure agreement which would have prevented it from informing its members about the bargaining process.

Bashneft systematically refused to engage in collective bargaining with the RCWU.

Acts of interference by employers16-08-2013

Benteler offered a significant premium payment to workers who had not participated in strikes.

Violence against union leaders31-03-2013

Valentin Urusov, a miner and a trade union leader from Yakutia in Russia’s north-eastern territory was arrested under the pretext that he was dealing in drugs. He was tortured and then sentenced to six years imprisonment. He was released in March 2013.

Inference in trade union activities31-01-2013

In January 2013, the Prosecutor declared that the ban on public activities at the Peugeot-Citroen plant was illegal. Management had prohibited the ITUA from distributing union leaflets among workers leaving the plant after their shift. Security guards physically attacked them and detained them in the parking lot.

Unions often denied registration 31-12-2011

Under the Federal Law on Trade Unions, Their Rights and Guarantees of their Activities, trade unions are registered as legal entities upon notification, and it is prohibited to deny registration. However, in practice the registrars often deny registration or require the unions to make changes to their statutes. For example, the registrars may view the requirement in the law to specify the geographical scope of the union’s activities as an obligation to provide a list of all the territories where affiliates exist, thus making it difficult for affiliates from other territories to join the union. The registrars can also require that regional unions specify all sectors where an affiliate can be created, although the law provides for no such requirements.

No effective system for defending trade union rights 31-12-2011

Defending trade union rights and stopping discrimination can be a gruelling experience. Trade unions’ appeals to prosecutors’ offices may not only go unanswered, but may even result in increased pressure on the unions. Going to court is only possible in cases of specific violations, and the procedure is both complicated and costly. Furthermore, even when a court rules in favour of the union, that does not alleviate the general situation, as trade union rights are constantly violated. Neither the Criminal Code nor the Code of Administrative Offences contains any special provisions on liability for violations of union rights.

There were a number of court rulings in 2011 concerning cases of trade union rights violations committed in previous years.
On 19 January, Tverskoy District court again refused to uphold an appeal by the Inter-regional Trade Union of Automobile Industry Workers (ITUA), affiliated to the Confederation of Labour of Russia (KTR) and the International Metalworkers’ Federation (IMF), which concerned the decision (in 2009) to include trade union materials into the Federal List of extremist materials.
On 18 January, the regional court of the Samarskaya region rejected the lawsuit brought by activists from the General Motors - AvtoVaz primary trade union organisation, who were fired without any consultation with the trade union in 2009.

In 2011, numerous claims by the activists of the primary trade union organisation at “Tikkurila” near St Petersbourg were rejected by the courts. A deputy chair of the trade union organisation, Igor Ramko, another deputy chair, Elena Rostovskaya, the members of the trade union Vyacheslav Vackulenko and Alexander Kalyniuk were dismissed in 2010, and their claims were rejected.

One of the cases in which a court refused to protect the human rights of trade union activists in 2011 was connected with the most outrageous and brutal example of repression against a trade union leader, the case of Valentin Urusov, a leader of the trade union organisation at ALROSA, the largest diamond company in Russia. The leader of the newly established trade union was sentenced to six years in jail in 2008, on trumped-up charge of storing drugs. Despite an international solidarity campaign, Valentin Urusov remains in jail. His appeal was rejected by the Supreme Court of the Republic of Sakha Yakutia on 30 June 2011.

Recourse to dispute resolution and strikes undermined31-12-2011

At least 263 protest actions occurred, including at least 91 collective work stoppages. The huge majority of these actions (around 92%) were held without observing the procedures and requirements of the Labour Code concerning collective labour disputes.

Recourse to dispute resolution and strikes undermined04-12-2010

Official statistics only indicate that a few strikes took place in 2010, but according to unofficial monitoring at least 205 protest actions occurred, including at least 88 collective work stoppages. The majority of these actions were held without observing the procedures and requirements of the Labour Code concerning collective labour disputes.

The unofficial actions are a result of the extensive restrictions and complicated procedures in the law; of unfair behaviour by many employers having no intention to negotiate with workers and resolve collective conflicts; and of blunt interference by the law enforcement bodies, which often support the employers, especially in small towns and isolated territories. Various tactics including pressure, intimidation and threats are also used by employers, prosecutors, officials of the Ministry of Internal Affairs and others to prevent workers and trade unions from accessing dispute resolution mechanisms and from going on strike.

As a result workers and trade unions do not believe that they can effectively use the legal procedures and thus prefer to organise other types of mass actions to attract the attention of the regional or federal government.

Trade union leaders face problems with access to workplace10-10-2010

The law grants external trade union representatives and inspectors the right to access workplaces, but this right is often ignored in practice. Some employers refer to governmental instructions regulating access to enterprises in their sectors to refuse to issue workplace passes, and when issued the trade unionists have to pay for them. Attempts to enlist the help of the public authorities have yielded little result. In 2009 the Federation of Independent Trade Unions of Russia (FNPR) addressed a request to the Prime Minister of Russia, Vladimir Putin, to draft a Federal Act providing for a procedure for access to workplaces. This petition was redirected to the Ministry of Health and Social Development, which eventually replied that the question requires additional discussions. An act has yet to be adopted.

Systematic and serious violations30-11-2009

Attacks on trade union leaders, government interference and persecution, denial of registration and recognition, anti-union harassment in the workplaces and lack of effort in investigating the violations of trade union rights are not isolated cases, but an everyday reality. This has prompted two national trade union centres, All-Russian Confederation of Labour (VKT) and Confederation of Labour of Russia (KTR) to prepare a comprehensive complaint to the ILO Committee on Freedom of Association. By the time of writing, the complaint has been submitted and then endorsed by the Federation of Independent Trade Unions of Russia (FNPR), the ITUC and the global union federations IMF, ITF and IUF.

Workers who join trade unions or engage in union activities are often mistreated by employers and authorities alike. While union members suffer from anti-union discrimination and pressure to relinquish their trade union membership, the leaders of grass-root organisations are subject to intimidation, harassment and even physical attacks. Since there are no special laws to protect freedom of association and the right to organise, trade unionists must make use of general legal procedures to protect their rights and liberties. Even though there have been some success stories of a conflict being settled or a wrongly dismissed leader reinstated, the existing mechanisms are considered ineffective.

National legislation is also being interpreted in a way that all cases of anti-union discrimination have to be reviewed by courts. Therefore, labour inspectorates, who are in principle entrusted with the task of overseeing compliance with the labour law, routinely dismiss complaints against anti-union behaviour, and appeals to the prosecutor’s offices have so far not been effective. Trade unions report that the existing system fuels a climate of impunity in the workplaces. Moreover, appeals to the prosecutor’s offices often do more harm than good, as prosecutors tend to side with the employers against the unions, and, after the investigation is concluded, anti-union pressure increases.

Interference with union affairs30-11-2009

Registration rules give law enforcement bodies extensive control over the content of trade union constitutions. Registrars often interpret the law in a manner that unions perceive as inappropriate, but failure to comply with the registrar’s comments will likely mean that the registration is delayed or denied. The law also requires the unions to specify the geographic scope of its activities. The registrars view this as an obligation to provide a list of all territories where the affiliates are active, and accepting affiliates from other regions would call for amendments to the union constitution.

Trade union leaders are often summoned by law enforcement bodies for different reasons. In most cases, this does not lead to further consequences and, in trade unionists’ view, are just used to pressurise and harass them. Occasionally, criminal charges are considered against the unionists. Tax inspections and auditions are not uncommon, and failure to provide documents such as lists of members may result in fines. Police officers are also after union rosters: for example, after an employee was murdered in a company in Togliatti, the investigators demanded the full list of members of grass root trade union organisations, even though there was no link between the unions and the murder.

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