ADC “Memorial” responded to procurator’s office, denied improper door sign and lack of noise levels’ measurements

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Given recent statements by the Russian deputy procurator general Alexander Buksman and the earlier comments by the Russian Ministry of justice that large scale checks of non-commercial organizations in Russia, which started in March this year throughout the country, are due to the wish of the state to uncover organizations failing to register as “foreign agents” while getting financial assistance from abroad, it is interesting to analyze the course of these checks on the example of ADC “Memorial”.

These checks of non-commercial organizations are carried out with the participation of various state organizations, including Federal Tax Service, Federal Migration Service, Ministry of emergency situations, police and others. On March 26, 2013 ADC “Memorial” was also visited by similar auditors. District deputy procurator Smirnov, head of the group that checked ADC “Memorial”, presented a letter addressed to the head of ADC “Memorial” (no name or even the exact title of the director of ADC “Memorial” was mentioned in the letter), which reads: “District procurator’s office carries out a check of how the legislation on counteracting extremism coming from public organizations, religious associations and unregistered public and religious associations of destructive and radical nature is observed”.

This official of local procurator’s office was accompanied by a representative of Rospotrebnadzor (Russian consumer watchdog) Mrs. Zabavina, Ministry of emergency situations inspector Mr. Fomin, two police officers from the Chief directorate of Ministry of the interior for Saint Petersburg and the local police station, who expressed their concerns about the licenses for software used by ADC “Memorial”. Police didn’t have any complaints regarding ADC “Memorial”, but Rospotrebnadzor and the Ministry of emergency situations have made interesting “statements” which were forwarded to us by the procurator’s office on April 4, 2013. Procurator’s office required explanations regarding these statements to be provided by the administration of ADC “Memorial”, but refused to provide us with a copy of these documents. We had to make photos of these documents using a mobile phone. Copies of these documents and our official response are provided as attachments to this report.

Administration of ADC “Memorial” categorically rejects all the claims made by the Rospotrebnadzor and most of the claims made by the Ministry of emergency situations. Some of them are simply absurd – for example, that the door sign at the entrance to ADC “Memorial” doesn’t feature “opening hours” of the organization and that this supposedly is in violation of the law on consumer rights adopted in 1992 (although the law concerns only those who provide their services on a paid basis). ADC “Memorial” doesn’t provide paid services. All of the information concerning our opening hours and contact details is provided on our website, as well as “Yellow Pages of Saint Petersburg”, which are accessible to people looking for our services. Some of the complaints made by Rospotrebnadzor and the Ministry of emergency situations – such as the width of doors, lack of “instrumental measurements of noise levels” and other potentially hazardous things – cannot be addressed to ADC “Memorial” because we are renting our office from a business centre.

However, the most important question is the following: what exactly is the connection between checking observation of legislation against extremism, as well as foreign financing, with the above mentioned peculiar subjects? It is also a mystery to us what is the connection between checking foreign financial assistance with the supposed violations of anti-extremist legislation? If, as Mr. Buksman has stated, financial sources of non-commercial organizations are being checked (which, by the way, doesn’t require participation of the Ministry of emergency situations, Rospotrebnadzor and others), why mention “extremism” at all? And as far as Rospotrebnadzor and the Ministry of emergency situations are concerned, is it correct to distract them from the real problems they have to deal with on a daily basis – starting from natural disasters to epidemics and noise levels? It is also worth mentioning that non-commercial organizations already provide detailed reports about sources of financing to the Ministry of justice in an orderly manner and no special audits and visits are necessary.

Here’s how our colleagues from human rights association “Agora” commented on such a “mixture of genres” concerning the checks initiated by the procurator’s office: “The statement made by the deputy procurator general implies that a foreign agent could be any organization which receives foreign financing, while the law clearly states that it should also be involved in political activities”. (See:

Ministry of emergency situations’ report about its participation in the check of ADC “Memorial”:

In official response provided to the Ministry of emergency situations by the director of ADC “Memorial” Olga Abramenko, it is stated that:

Concerning paragraph 1: On January 10, 2008 regulations concerning health and safety of employees were adopted by director’s order, the first part of it being instructions concerning fire safety.

Paragraph 2: On July 1, 2007 by director’s order a person responsible for fire safety was appointed.

Paragraph 3: Director of ADC “Memorial” has completed the minimal training course on fire and technical safety, which was organized by the administration of the business centre in which ADC “Memorial” rents its office.

Paragraph 4: Instructing employees on fire safety is being carried out initially (when signing labor agreement) and on a recurring basis (once every half a year, which is registered in a special notebook).

Paragraph 5: Printed instructions on fire safety, which include emergency telephone numbers to call fire fighting brigades, are posted on office walls.

Paragraphs 8, 9, 10: Violations mentioned in the report (including the use of an electric power filter with a damaged case, use of a lamp without proper dispersion, placement of lamp closer than 0.5 m from the flammable materials) were eliminated on the same day, while inspectors were still in our office.

Paragraphs 6, 7, 11: Violations mentioned in the report (door width below 0.8 m, double tambour doors, lack of fire-proof wall between rooms of various use, such as office and storage rooms) are architectural characteristics of the building in which we rent offices, thus ADC “Memorial” doesn’t accept its responsibility for their elimination. Besides that double tambour doors are prohibited in offices where 15 or more people are working, while in ADC “Memorial” respective figure is less than 15.

Official response of ADC “Memorial” to Rospotrebnadzor (in Russian):

Media reports about the check in ADC “Memorial” (In Russian):