Code of Business Conduct and Ethics

Honest and ethical behavior


We are committed to doing business honestly and ethically and do not tolerate fraud or dishonest behavior of any kind.


Thus, our core values ​​are the key principles that guide our behavior and our relationships. They guide how we conduct our business and interact with our employees, customers, agents, business partners and other stakeholders, while striving for operational and financial excellence. Each of us has a responsibility to ensure that our behavior is consistent with our core values.


The Code cannot describe all standards related to honest and ethical behavior. We are responsible for our actions. If we do come across anything which we are not sure about, we should not hesitate to ask questions about whether any conduct may violate the Code, voice concerns or seek to clarify grey areas.


The process through which the results are achieved is as important as the results themselves. We must foster a culture where we do not condone any compromise on issues of integrity.


Compliance with laws. Non-discrimination


In our activities, we are guided by the requirements of the legislation of the Russian Federation and the provisions of national, regional and local laws, as well as the norms and customs of international law. In relations with our customers, partners, agents, we do not discriminate based on jurisdiction, age, race, religion, national origin, ethnic and social origin, gender, marital status, physical or mental qualities. The only restrictions for us may be the requirements of the legislation of the Russian Federation.


Privacy Policy


In our activities, we strictly adhere to the confidentiality policy in relation to all projects we carry out with all our clients, customers, suppliers, agents and other business partners. Our policy provides for the principle of non-disclosure of any details of transactions and operations on this project to any third parties not directly involved in such a transaction. We do not publish the names and details of our partners, agents, customers, customers, suppliers and experts.


Personal data


We respect the privacy and personal data of all employees, business partners and customers. We comply with all applicable laws and regulations on the collection, use, protection and transfer of personal data.


We must handle all personal information responsibly in accordance with policy and/or applicable data protection or privacy laws and regulations within the countries in which we operate. In case we have access to personal data we must only use it for authorized purposes, share it with authorized persons and organisations and hold the information for only as long as is necessary for such purposes.


Security over information and assets


Assets can be physical, financial, informational or intangible and include but not limited to buildings, equipment, funds, software, records, customer information, know-how, trademarks, patents and other intellectual property. We must all treat and use assets responsibly, for legitimate business purposes and protect them from waste, loss, damage, theft, unauthorized disclosure, mis-use or infringement.


To protect assets, premises, data, information systems and networks from threats and competitors, security policies have been implemented in all departments of the Company. We have a duty to be familiar with our security policies and regulations and to observe all security and access arrangements at our premises and facilities including the use of information and communications equipment and systems.


Security is everyone’s responsibilities. We must be alert and report any security threats (whether physical or cyber) promptly in accordance to policies and procedures.


We have a responsibility to ensure that we maintain accurate, timely and complete records and accounts. We maintain and preserve our financial and business records in accordance with accounting and record keeping policies, applicable laws and regulations.


We keep records of transactions, expenditures, labor charges, all kinds of fees and all other aspects of the business accurately and in accordance with these policies and applicable laws of the Russian Federation.


Third party information


We respect the rights and assets of others, including their proprietary information and intellectual property. The unauthorised use of such information or the intellectual property of others — including competitors, customers, or suppliers — could be embarrassing and would damage our reputation and risk legal action. We must obtain proper authorization in accordance with company policies (and, if in doubt, consult with your Legal Department) before soliciting, accepting or using the proprietary information or intellectual property of others.


Inside information and public disclosure


“Inside information” is non-public information which, if made public, would likely affect its a company reputation and goodwill.


We must not communicate such inside information to another person, whether family members, friends or business associates. Our employees who may have access to such inside information in their daily work should be aware of the principal rules for treating inside information.


Quality and safety


Our customers must be able to rely on products and services we offer to them to perform their intended functions satisfactorily. The products for supplies must be safe to produce, safe to operate and safe to maintain. We deliver safe products and services through the proper application of product safety policies, laws and/or procedures. We will ensure the supplied products are designed and manufactured, and our services provided, in a manner that seeks to reduce the risk of hazard to operators, the public, property and the environment.


Zero tolerance for corruption


Corruption or bribery occurs when you offer, give or promise to give, seek or accept a payment, gift, favor or other advantage – directly or indirectly:

• as an inducement or reward to take (or refrain from taking) any official action or

• for any improper business advantage or

• to influence a business outcome in the conduct of business.


We do not tolerate corruption of any kind whether relating to private individuals, government officials, private companies or public organisations. We comply with all bribery and anti-corruption laws in any country where we operate. We must not offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or any person for the purpose of obtaining or retaining business or an improper advantage.


Likewise, we must never solicit or accept a bribe or kickback from a public official or any person. In addition, we must not hire others to do anything that we cannot ethically or legally do ourselves.


Payments made to government officials to expedite or perform a routine administrative action are not permitted. These payments, sometimes known as “facilitation payments,” are illegal under most local anti-corruption laws, and regardless, these payments are against our policy and will not be tolerated.


Government or public official is:

• An employee of any government or state owned entity.

• An official of a political party and candidates for political office.

• A person holding a legislative, administrative or judicial office of a given country (including all levels and subdivisions of government, from national to local), whether appointed or elected.

• Officials of public international organisations.


We consider facilitation payments as small unofficial payments which are usually made to low-level public officials to speed up or obtain routine administrative processes.


We must ensure that all our agents or any third party intermediaries are evaluated and appointed in accordance with our Company policies.


Conflicts of interest


Conflicts of interest happen where two or more competing interests conflict and impair our ability to make objective, unbiased business decisions. A conflict of interest can take many forms, including managing or recruiting a relative; having an outside employment; having financial interests in suppliers or holding director appointments with an outside business without the Company’s approval.


The mere appearance of a conflict of interest can be damaging to our reputation, even where no conflict actually exists, and should be avoided. We must refrain from any practices or involvement that could lead to, or be perceived as, a conflict of interest.


As soon as we are aware, we will declare all outside activities, interests or relationships which may conflict or appear to conflict with our performance and take prompt and appropriate actions (such as removal from involvement in the transaction) to address such conflict in accordance with the respective implemented processes.


The existence of a conflict of interest can be unclear. If we have any questions about a potential conflict of interest, we should discuss the issue with the local Compliance Officer or Legal Department.



Trade embargoes, sanctions and export controls


There are national and international laws and regulations governing importing and exporting products, services, technology and information.


Additionally, controls and sanctions (or embargoes) can be imposed against countries, entities, individuals and goods.


Persons involved in the import or export of goods and services with us should be aware of the policies and procedures for handling goods, technology and data. In any case of doubt or queries, we should contact our relevant experts and compliance officers for clarification.


We must ensure that customers, suppliers and business partners whom we do business with are screened against local and international sanction lists in accordance with our policies. Approval must be sought for transactions with parties that are subject to US, UN or European Union Sanctions in accordance with the respective implemented procedures.


Competition, antitrust and fair dealing


Competition, antitrust and similar laws aim to ensure a free and competitive market. Some of these laws are complex in their application and may have a global reach. They prohibit agreements, decisions by associations and concerted practices that undermine competition and the abuse of a dominant market position by companies. They also require fair dealing.


We are committed to conduct our business in a fair, honest and ethical manner, in all our dealings with customers, suppliers, partners and competitors in compliance with applicable law.


We must not discuss, agree nor have any understanding with competitors on pricing, fixing any elements of price (such as discounts, rebates or surcharges), bid rigging, market sharing / division, allocation of customers, limit or control production.


We must comply with all applicable competition, antitrust and fair dealing laws and if in doubt, consult with or seek clarifications from legal department. Any failure to comply with these laws can severely damage our business and reputation as well as expose us, in some cases, to criminal prosecution and penalties.