General Provisions

The policy in the field of compliance system management defines the basic principles and objectives of the compliance system aimed at preventing the risks of bringing to various types of liability due to non-compliance with legal requirements, negative property and reputation consequences. The purpose of the compliance policy is to strengthen business reputation, promote honest and ethical business conduct and prevent abuse.

Principles of the Compliance System

The Company considers unacceptable any manifestations of corrupt practices in the course of their professional activities. Intolerance of corruption means a strict prohibition for any persons acting on behalf of the company or in its interests, directly or indirectly, personally or through any intermediary. The consequences of corruption actions for Society include: Significant reputation risks: reduced trust on the part of government agencies and Counterparties; Inability to obtain performance under contracts concluded as a result of illegal actions; Application of criminal, civil or administrative liability measures in accordance with the legislation of the countries in which the Company operates. 

The consequences of corrupt actions for employees include: The application of disciplinary measures, including dismissal; The application of criminal, civil or administrative liability measures in accordance with the legislation of the countries in which the Company operates.

Compliance System Tools

The principles of the compliance system are implemented through the implementation and application of the following tools in the company's current activities: risk assessment of the company. The Company implements and ensures continuous identification and assessment of risks threatening the compliance system, determination of the causes and consequences of non-compliance with the established requirements. 

Internal regulations of the Company in the field of compliance system: The Regulation on internal Control over the Financial and Economic Activities of the Company; the Code of Corporate Ethics; the Regulation on Mandatory Verification of the Company's Counterparties; The Company's Compliance Policy; the Company's Regulation on Compliance with Anti-Corruption Legislation; Anti-corruption clauses in contracts with Counterparties. Taking into account the results of the assessment and in order to reduce risks, the Company's internal regulations in the field of the compliance system should: Reflect the Company's values in the field of the compliance system; Contain provisions on liability for violations.

Employee Policy

Training and evaluation of personnel. The Company implements assessment procedures according to the standards of professional suitability when applying for a job, as well as within the framework of career promotion procedures in accordance with the requirements of applicable legislation. The Company develops and implements compliance training programs for all employees. Training programs are formed based on the level of employees' exposure to certain risks. When performing their official duties, the company's managers and employees must be independent of the conflict of interests affecting the company or them personally. 

Personnel ensuring the functioning of the Compliance System. Employees who are assigned tasks in the field of the Compliance System include employees of the legal department, senior management, as well as directly the General Director of the Company. Employees performing internal control functions provide the General Director with all requested information and documents for the purpose of reliable accounting of transactions and are guided by the instructions of the General Director regarding improvements to the Company's internal control system. 

Relations with Counterparties  

The Company conducts checks on each prospective business partner both at the negotiation stage and during the period of cooperation. The verification of the business partner should be carried out taking into account the risks associated with the specifics of the business partner's business activities. Verification of a business partner should, at a minimum, take into account and evaluate: Legal capacity /capacity; Solvency; Country, beneficial owner, organizational structure; Business reputation; Communication with government agencies, organizations, officials. Based on the results of the audit, the Company may withdraw from contractual relations or terminate contractual relations with a business partner in accordance with the procedure established by applicable law, as well as directly by the contract.