Anti-corruption policy

Scope

The Anti-Corruption Policy (hereinafter the “Policy”) stipulates the key principles and requirements for corruption prevention and compliance with the applicable anti-corruption laws by the management of ООО «СТЭП ЛОДЖИК» (hereinafter the “Management”), the Employees, and other persons who can act on behalf of ООО «СТЭП ЛОДЖИК».
The Policy is an internal regulation of ООО «СТЭП ЛОДЖИК» (hereinafter the “Company”) developed and adopted in accordance with the anti-corruption laws, as well as the Articles of Association and other regulations of the Company.
The Policy is a documented procedure of the quality management system.
The requirements hereof shall be mandatory for all Employees of ООО «СТЭП ЛОДЖИК» (hereinafter the “Employees”) in positions according to the organizational chart employed both full-time and part-time, as well as for representatives of the company and other persons with relevant contractual obligations.
This Policy shall become effective as of its approval and shall remain in force until its replacement with a new Policy. The current policy shall be amended by a company order.

Regulatory Reference

This policy uses references to the following regulatory documents:

• Federal Law On Combating Corruption No. 273-FZ of 25/12/2008
• Foreign Corrupt Practices Act (FCPA)
• United Kingdom Bribery Act (UK BA)
• Criminal Code of the Russian Federation
• Administrative Offences Code of the Russian Federation Federal Law No. 195-FZ of 30/12/2001
• VP_PL_04 Conflict of Interest Regulation
• VP_PL_02 Compliance Control Regulation

Abbreviations and Symbols

For the purpose hereof, abbreviations and symbols shall be used in accordance with the Reference Book of Terms and Definitions posted on the corporate website at Home > Document centre> Terms and definitions.

Terms and Definitions

For the purpose hereof, terms and definitions shall be used in accordance with the Reference Book of Terms and Definitions posted on the corporate website at Home > Document Centre > Terms and definitions, including:

• Anti-corruption laws shall mean a body of laws in force in the Russian Federation and other countries where the company does business itself or via its business partners; laws governing public, economic, civil relations, as well as other laws and regulations providing for measures to prevent and curtail corruption offences, and for liability for such offences.

Anti-Corruption Policy

Applicable anti-corruption laws

• The Company, its Management and Employees shall comply with the anti-corruption laws, including Federal Law On Combating Corruption No. 273-FZ of 25/12/2008, the Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UK BA), the Criminal Code of the Russian Federation, the Administrative Offences Code of the Russian Federation Federal Law No. 195-FZ of 30/12/2001 and other laws and regulations with key provisions concerning:
  • Prohibition of active bribery, i.e. prohibition of providing or promising to provide any financial or other benefits/advantages with the intent to induce any person to improperly perform their duties.
  • Prohibition of bribetaking, i.e. prohibition of accepting or consenting to accept any financial or other benefits/advantages for improper performance of one's duties.
  • Prohibition of corrupt business practices, i.e. prohibition of providing or promising to provide (directly or via third parties) any financial or other benefits/advantages to an official/government official to influence the performance of their official duties to acquire/retain business or to ensure competitive or other advantages for the company.
  • Prohibition of mediation in and toleration of bribery, i.e. availability of the company's adequate procedures for preventing active bribery or bribetaking by any persons related to the company in order to acquire/retain business or to ensure commercial and competitive advantages.

General Provisions

• The Management and all Employees shall be strictly prohibited from directly or indirectly, in person or via third parties engaging in corrupt practices, offering, giving, promising, soliciting and taking bribes or making any payments to simplify statutory, regulatory and other formalities in any manner, including in the form of money, valuables, services or another benefits for themselves or any third parties and organisations, including commercial organisations, government agencies, local authorities and government officials.
• Policy Objectives.
• The Policy reflects the commitment of the Company and its management to high standards of ethics and principles of open and fair business, as well as the ambition to improve the corporate culture, follow the best practices of corporate governance, and protect the Company's business reputation.
• The Company sets the following objectives:
  • To minimize the risk of involvement of the Company, its Management, and Employees, regardless of the position held, in corrupt practices.
  • To create consistent understanding of the Company's policy of zero tolerance for all and any corrupt practices by the Counterparties, Employees, and other persons.
  • To summarize and explain to all Employees the basic requirements of anti-corruption laws applicable to the Company, its Management and Employees.
  • To establish the Employees’ responsibility to know and comply with the principles and requirements hereof, the key provisions of the applicable anti-corruption laws, as well as to participate in anti-corruption measures.
• Management’s Mission.
  • The Management, including the CEO, shall create an ethical standard of zero tolerance for all and any corrupt practices at all levels acting as role models and ensuring awareness and understanding of the anti-corruption policy by all Employees and Counterparties.
  • The Company shall establish the principle of zero tolerance for all and any corrupt practices in the day-to-day activities and strategic projects, including in cooperation with the Counterparties, representatives of government agencies, local authorities, political parties, its Employees and other persons.
• Periodic Risk Assessment. The Company shall periodically identify, review, and assess corruption risks specific to its activities in general and to certain areas in particular.
• Adequate Anti-Corruption Measures.
  • The CEO shall be responsible for organizing all measures intended to implement the principles and requirements hereof, including appointment of persons responsible for development, implementation, and control of anti-corruption measures at the Company.
  • The Company shall take anti-corruption measures reasonably adequate to the risks identified.
• Counterparties’ Due Diligence. The Company shall make reasonable efforts to minimize the risk of business relations with the Counterparties that may be involved in corrupt practices. To that end, the Company shall examine the Counterparties’ tolerance of bribery, including their willingness to include anti-corruption clauses in contracts and to provide mutual assistance for ethic conduct of business and prevention of corrupt practices.
• Awareness and Training.
  • The Management and its designated officers shall communicate this Policy to all Employees, explain and clarify the requirements hereof in relation to the functions of the Employees.
  • The Employees’ shall be informed and trained pursuant to the annual plan developed by the Compliance Controller and formally approved by the CEO. The Compliance Controller shall be appointed in accordance with VP_PL_02 Compliance Control Regulation.
    • The Company shall openly declare zero tolerance for corrupt practices, welcome and encourage compliance with the requirements and principles of the anti-corruption laws by its Employees and Counterparties.
• Monitoring and Control. Due to possible evolution of corruption risks and other factors affecting business activities, the Company shall monitor the adequate measures implemented to prevent corrupt practices, control their performance, review and improve them if necessary.

Gifts and Official Entertainment Expenses

• Gifts and official entertainment expenses related to business hospitality that the Employees can incur on the Company's behalf for other persons and organisations or that the Employees can receive from other persons and organisations in connection with their work at the Company shall meet the following requirements:
  • They shall be directly related to the legal objectives of the Company's operation, e.g., presentation or completion of business projects, successful performance of contracts or to the national holidays, the Company’s birthday;
  • They shall be reasonable and justified;
  • They shall be approved by the company’s management;
  • They shall not represent a secret reward for a service, action, omission, toleration, favour, granting of rights, certain decision on a deal, agreement, authorization, etc. or an attempt to influence the recipient with another unlawful or unethical purpose;
  • They shall not create reputation risks for the Company, its Employees, and other persons in case of disclosure of information on gift expenses or official entertainment expenses;
  • They shall not contradict the principles and requirements hereof and of other regulations of the Company, the legislation of the Russian Federation.
• The Company, its Employees and representatives may not make a gift of money, whether in cash or not, in any currency to third parties.
• Souvenirs (products of low price) with the Company's logo provided at exhibitions, open presentations, forums and other official marketing events shall be allowed and considered as marketing or information materials.

Conflict of Interest

• The Company, its Management and Employees shall refrain from any action which can cause a conflict of interest for any of their Business Partners and Counterparties.
• In case of the Employee’s conflict of interest, they shall advise the Company thereof in accordance with VP_PL_04 Conflict of Interest Regulation.
• When investigating a conflict of interest, the designated persons shall act in accordance with VP_PL_04 Conflict of Interest Regulation.

Participation in Charity

• The Company shall not finance any charitable and social projects to gain specific commercial advantages.
• Information about charitable and social activities shall be published on the Company's website or shall be disclosed otherwise.
• The Company may decide to participate in charity events aimed at creating the reputation of the organisation as a corporate citizen, provided that the budget and the event participation plan are approved by the CEO.

Involvement in Politics

• The Company shall not finance any political parties, organisations and movements.

Engagement with Government Officials

• The Company shall refrain from compensating any expenses of government officials and their immediate relatives (or in their interests) to obtain commercial advantages in certain projects, including expenses for transportation, accommodation, meals, entertainment, PR campaigns, etc. or from providing other benefits at the expense of the Company.

Engagement with the Employees

• The Company shall demand that its Employees comply herewith while informing them of the key principles, requirements, and sanctions.
• Periodic events for raising the Employees’ anti-corruption awareness shall be held in face-to-face and/or remote form.
• Compliance of the Company's Employees with the principles and requirements hereof shall be taken into account when creating a candidate pool for promotion to superior positions, as well as when imposing disciplinary sanctions.

Engagement with Intermediaries and Third Parties

• The Company and its Employees shall be prohibited from engaging or using intermediaries, partners, agents, joint ventures or other persons for any actions contrary to the principles and requirements hereof or to the provisions of the anti-corruption laws.
• To comply with the principles and requirements hereof, the Company shall offer to include anti-corruption terms (clauses) in contracts with intermediaries, counterparties, partners, agents and other parties.

Record Keeping

• All financial transactions shall be exactly, correctly and with sufficient detail included in the Company’s book records, documented and available for review.
• The Company shall appoint the Employees to bear personal responsibility provided for by the current legislation of the Russian Federation for preparation and presentation of full, reliable and timely book records in accordance with the applicable laws.
• Misrepresentation or falsification of the Company's book records shall be strictly prohibited and regarded as fraud.

Informing about Policy Weaknesses

• Any Employee or another person shall inform its superior of any doubts about the legality or compliance of their actions, as well as any action, inaction or offer of other Employees, counterparties or other parties interacting with the Company, with the objectives, principles, and requirements hereof, and the superior shall provide, if necessary, recommendations and explanations concerning the situation.

No Sanctions

• The Company declares that no Employee will be subject to sanctions (including dismissal, demotion, loss of a benefit) for reporting suspected corrupt practices or refusing to give or take a bribe, engage or mediate in commercial or any other bribery, regardless whether the Company has incurred any loss of profits or has not obtained commercial and competitive advantages as a result of such a refusal.

Audit and Control

• The Company shall regularly conduct an external audit of financial and business activities, control the completeness and correctness of data in book records and compliance with the requirements of the legislation of the Russian Federation and regulations governing the Company's processes, including compliance with the principles and requirements set forth hereby.

Amendments

• If the provisions hereof or the Company’s anti-corruption measures are discovered to be insufficiently efficient, or in case of amendments to the anti-corruption laws, the CEO and the designated persons shall ensure development and implementation of an action plan to revise and amend this Policy and/or the Company’s anti-corruption measures.
• Amendments hereto shall be made in accordance with the rules set forth by the Company.

Liability for Non-Compliance

• All Employees, regardless of their position, shall be held personally liable for compliance with the principles and requirements hereof, as well as for the actions (inaction) of their subordinates violating these principles and requirements.
• The liability for non-compliance with the anti-corruption policy shall be set forth in accordance with the current legislation of the Russian Federation.
• The Company shall conduct internal reviews and investigations concerning each probable cause or established fact of corrupt practices in accordance with VP_PL_02 Compliance Control Regulation.