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Anti-corruption Policy Regulations of the Company

The Company, taking account of the provisions of Federal Law No. 273-FZ of December 25, 2008 “On Combating the Corruption”, and implementing the National Anti-Corruption Strategy (approved by Presidential Decree No. 460 of April 13, 2010) hereby approves the anti-corruption policy of the Company, the principles of behavior regarding the corruption of its employees, counterparties and other persons.

1. By the term “corruption” the Company means: abuse of official position in the Company, giving a bribe, accepting a bribe, abuse of authority, commercial bribery, unofficial material incentives to counterparties of the Company or persons influencing the actions of counterparties of the Company or their management bodies with a view to adoption of decisions by such counterparties, that are favorable to the incentivizing person, or other illegal use by an individual of his official position contrary to the legitimate interests of the organization, society and the state for the purpose of obtaining benefits in the form of money, valuables, other property or services of the property nature, other property rights for oneself or for third parties, or the unlawful provision of such benefits to the specified person by other individuals.

2. The Company carries out anti-corruption actions within its powers:

- on the prevention of corruption, including the identification and subsequent elimination of the causes of corruption (prevention of corruption, circulation of information and legal materials to the Company's employees);

- identification, prevention, suppressing, solving and investigating of corruption manifestations within the Company (fighting corruption within the Company);

3. Corruption manifestations, in any form, may not be approved, encouraged or funded by the Company.

Every employee of the Company, regardless of the position he holds, is obliged to inform the Director General of the Company about any corruption manifestations. Such a message should be in the form of a service memo.

All employees of the Company should be informed by the heads of subdivisions that corruption manifestations (actions) entail bringing the individual who has committed such actions to disciplinary or criminal responsibility, as well as to civil liability in accordance with the current legislation of the Russian Federation.

4. The Director General and / or heads of subdivisions of the Company do not have the right to give orders to employees aimed at the implementation of corruption practices.

5. Employees of the Company are not entitled to make corrupting offers to representatives of counter-parties or regulators.

6. An employee of the Company is obliged to notify the Company of cases that have become known to him in connection with the performance of his official duties that contain signs of corruption practices. In case of non-fulfillment of this duty, the employee shall be brought to disciplinary, civil or criminal liability, in accordance with the current legislation of the Russian Federation.





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