1. PURPOSE OF THE DOCUMENT

1.1. This Anti-Corruption Policy (hereinafter referred to as “the Policy» ) is the basic document of «Prisyazhnyuk’s Group. Investment Management» CJSC (hereinafter referred to as «the Company»), outlining key principles and requirements for the prevention of corruption and compliance with applicable anti-corruption laws for the Company, members of their governing bodies, employees and other persons who may act on behalf of the Company.

1.2. The policy was developed in accordance with the legislation of the Russian Federation, the Charter and other internal documents of «Prisyazhnyuk’s Group. Investment Management» CJSC.

2. POLICY GOALS

2.1. The Policy reflects the commitment of the Company and its management to the highest ethical standards of open and honest businesses to improve corporate culture, follow the best practices of corporate governance and the business reputation of the Company at the proper level.

2.2. The Company’s goals are to:

• Minimize the risk of involving the Company, the Executive authority of the Company and the Company’s employees regardless of their position (collectively referred to as «Employees») in corrupt activities.

• Give the shareholders, the investment community, contractors, Employees, members of their governing bodies, workers and other persons a common understanding of the Company’s policy of rejection of corruption in all its forms and manifestations.

• Summarize and explain the basic requirements of anti-corruption laws of the Russian Federation which can be applied to the company and Employees.

• Make it obligatory for the Employees of the Company to be acquainted and comply with the principles and requirements of this Policy, the key rules of the applicable anti-corruption laws, as well as with adequate procedures of preventing corruption.

• Summarize and explain the basic requirements of anti-corruption laws of the Russian Federation, which may apply to the Company.

3. SCOPE AND RESPONSIBLITIES

3.1. All Employees should follow this policy and abide scrupulously by its principles and requirements.

3.2. The General Director is responsible for organizing all the activities aimed at implementing the principles and requirements of this Policy, including the appointment of persons responsible for the development of anti-corruption procedures, their implementation and monitoring.

3.3. The principles and requirements of the present Policy apply to contractors and representatives of the Company, members of management and employees, and other persons, in cases where the corresponding duties are confirmed in treaties with them, in their internal documents, or derive directly from the law.

4. APPLICABLE ANTI-CORRUPTION LEGISLATION

4.1. The Company and all its Employees must comply with the rules of Russian anti-corruption legislation established by such documents as the Criminal Code of the Russian Federation, the Russian Federation Code of Administrative Offences, the Federal Law «On Combating Corruption» and other regulations, which are based on the prohibition of bribery and accepting bribes, as well as of commercial bribery and bribery mediation.

4.2. The main requirements of the present Anti-Corruption Policy are formulated as :

4.2.1. prohibition of bribery, i.e. providing or offering to provide any financial or other benefits / advantages with the intent to induce a person to perform his duties improperly;

4.2.2. prohibition of accepting bribes, i.e. receiving or accepting to receive any financial or other benefits / advantages for the execution of one’s duties improperly;

4.2.3. prohibition of bribery of public officials, i.e. providing or promising to provide (directly or through third parties) to a public servant any financial or other benefits / advantages to affect the performance of their official duties, to obtain / retain business or provide a competitive or other advantage for a commercial organization;

4.2.4. prohibition of condoning bribery, i.e. lack of adequate procedures in a commercial organization to prevent the giving or receiving of bribes by a person associated with such organization in order to acquire or retain business, to provide commercial and competitive advantages.

4.3. According to the legislation of the Russian Federation, «corrupt practices» are identified with giving or receiving bribes, mediation in giving or receiving bribes, abuse of authority or, commercial bribery, payments for facilitation, illegal use of one’s official position to obtain benefits in the form of money, values , and other property, as well as services, any rights for themselves or for other persons or illegal provision of benefits or rights to that person by the third parties.

4.4. Based on the foregoing, all Employees of the Company are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, to engage in corrupt activities, offer, give, promise, seek and receive bribes or make payments to simplify the administrative, bureaucratic and other formalities, in any form, including in the form of cash, property, services or other benefits for and from any persons or organizations, including business, government and self-government, government officials, private companies and their representatives.

4.5. The Company and its Employees must comply with anti-corruption laws of the Russian Federation, as well as the principles and requirements of the Policy.

5. KEY PRINCIPLES

5.1. The mission of the Company’s management
The General Director and other senior officers of the Company shall form an ethical standard of uncompromising attitude to all forms and manifestations of corruption at all levels, setting an example by their own behavior.
The Company establishes the principle of rejection of corruption in all its forms and manifestations (the principle of «zero tolerance») in carrying out daily activities and strategic projects, including in cooperation with shareholders, investors, contractors, authorities, local governments, political parties, the Company Employees, and other persons.

5.2. Periodic assessment of risks
The Company identifies and periodically updates the indicators of corruption risks associated with its operations and potentially vulnerable business processes.

5.3. Adequate anti-corruption procedures
The company develops and implements adequate procedures to prevent corruption, which reasonably correspond to the identified risks and monitor compliance.

5.4. Checking counterparties
The Company makes reasonable efforts to minimize the risk related to the business relationships with contractors that may be involved in corrupt activities. In order to do this, the counterparties’ tolerance to bribery must be assessed, including checking their having their own anti-corruption policies or procedures, their willingness to comply with the requirements of this Policy and include anti-corruption reservations in contracts and provide mutual support for ethical business practices and preventing corruption.

5.5. Communication and training
The Company publishes this Policy and makes it available on the corporate website on the Internet, openly declares rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Policy for all contractors, the Company’s Employees and other persons, and helps to raise anti-corruption culture by educating and training people.

5.6. Monitoring and control
The company monitors the implementation of adequate procedures to prevent corruption, controls compliance and improves them if necessary.

6. GIFTS AND REPRESENTATIONAL EXPESES

6.1. Gifts and entertainment expenses, including business hospitality that the Employees may grant to other persons and organizations on behalf of the Company, or that the Employees may receive from other individuals and organizations in connection with their work for the Company must comply with the aggregate five criteria listed below:

• be directly related to the legitimate purposes of the Company, for example, presentation or completion of business projects, conferences, successful execution of contracts, or to conventional holidays, such as Christmas and New Year, International Women’s Day, anniversaries, etc.;

• be reasonably justified, proportionate and not be luxurious;

• not constitute a disguised fee for a service, action, inaction, connivance, patronage, granting of rights, certain decisions about the transaction, agreement, license, permit, etc. or attempt to influence the recipient for any other illegal or unethical purpose;

• not create any reputational risk for the Company, its Employees and other persons in the case of disclosure of information about gifts or expense accounts ;

• be consistent with the principles and requirements of this Policy, other internal documents of the Company and applicable laws.

6.2. Gifts in the form of souvenirs ( low cost production) with the symbols of the Company, provided at exhibitions, public presentations, forums and other marketing activities the Company participates in officially must be admitted and treated as image materials.

6.3. Gifts on behalf of the Company, its Employees and representatives to third parties in the form of cash or non- cash, in any currency, are not allowed.

7. CHARITY AND SPONSORSHIP

7.1. The Company does not fund charity and sponsorship projects in order to obtain commercial advantages in its specific projects.

7.2. Information about the charity and sponsorship activities is published on the Company’s website on the Internet, in the Social Report, or otherwise disclosed.

8. PARTICIPATION IN POLITICAL ACTIVITIES

8.1. The Company does not finance political parties, organizations and movements in order to obtain commercial advantages in specific projects.

9. INTERACTION WITH STATE OFFICIALS

9.1. The company refrains from paying any costs for state officials and their close relatives (or in their interests) in order to obtain commercial advantages in specific projects of the Company, including the costs of transportation, accommodation, meals, entertainment, PR-campaigns, etc. or their receiving other benefits at the expense of the Company.

10. INTERACTION WITH EMPLOYEES

10.1. The Company demands that its Employees abide by this Policy, informing them of the key principles, requirements and sanctions for violations.

10.2. As part of the formation in the Company of an appropriate level of anti-corruption culture, periodic information sessions for Employees are conducted in person and / or remote form, as well as introductory training on the provisions of this Policy and related documents — for all new Employees of the Company.

10.3. The Employees’ compliance with the principles and requirements of this policy is taken into account for the formation of personnel reserve for promotion to higher positions, as well as the imposition of disciplinary sanctions.

11. PAYMENTS THROUGH INTERMEDIARIES OR IN FAVOR OF THIRD PARTIES

11.1. The Company and its Employees are prohibited to involve intermediaries, partners, agents, joint ventures or other persons to commit any actions that are contrary to the principles and requirements of this Policy or regulations of applicable anti-corruption laws.

11.2. The Company shall ensure verification procedures for intermediaries, partners, agents, joint ventures and other entities to prevent and / or detect violations described above in order to minimize and suppress risks of involving the Company in corrupt activities.

12. KEEPING ACCOUNTING BOOKS AND RECORDS

12.1. All financial transactions must be reflected in the Company’s accounting policies accurately, correctly and with a sufficient level of detail as well as documented and available for inspection.

12.2. The Company has appointed employees who are personally responsible for the preparation and submission of complete and accurate financial statements in terms set up by the applicable legislation.

12.3. Misrepresentation or falsification of financial statements of the Company are strictly prohibited and considered as fraud.
13. NOTIFICATION OF DEFICIENCIES

13.1. When any Employee or other person doubts the legality or ethics of their actions as well as actions, omissions or suggestions of other Employees, contractors or other persons who interact with the Company, they can report it to the «hotline» of the Company within program of notification about violations and shortcomings called «UNITED HOTLINE «. Information about the program is available on the Company’s website. They can also report it to their immediate supervisor, who, if necessary, will provide guidance and clarification on the situation.

14. DISCLAIMER OF RESPONSE MEASURES AND SANCTIONS

14.1. The Company states that no Employee will be subject to sanctions (including firing, demoting, depriving of awards) if they reported on alleged corruption, or refused to give or receive a bribe, to commit commercial bribery or provide mediation of bribery, including if such a failure resulted in lost profits or not receiving commercial and competitive advantage by the Company.

15. AUDIT AND CONTROL

15.1. The Company conducts regular internal and external audits of financial and economic activities, monitors the completeness and correctness of reflection of the data in accounting as well as compliance with applicable laws and internal regulations of the Company, including the principles and requirements set out in this Policy.

15.2. As part of the internal control procedures, the Company’s key business processes should be monitored, including spot checks on the legality of payments, their economic feasibility, feasibility costs, including confirmation by primary records and compliance with this Policy.

16. REPORTING

16.1. The General Director of «Prisyazhnyuk’s Group. Investment Management» periodically reviews management reports on the progress of ensuring compliance of the Company and its Employees with the principles and requirements of this Policy and rules of applicable anti-corruption laws.

17. CHANGES

17.1. In identifying underperforming this Policy or related business processes of the Company, or in case of changing the requirements of the applicable law of the Russian Federation, the General Director organizes the development and implementation of an action plan on updating this Policy and / or business processes.

18. LIABILITY FOR NON-IMPLEMENTATION OR INADEQAUTE IMPLEMENTATION OF THIS POLICY

18.1. The General Director and staff of all structural units of the Company, regardless of their position, are personally responsible for compliance with the principles and requirements of this Policy, as well as actions (omissions) of their subordinates who violate these principles and requirements.

18.2. As the Company may be subject to sanctions for participation of its Employees, contractors, and other persons in corrupt activity, for each reasonable suspicion or revelation of corruption, official investigations must be initiated to the extent permitted by applicable law.

18.3. Persons guilty of violation of the requirements of this Policy may be subject to disciplinary, administrative, civil or criminal liability under the Company’s initiative, law enforcement or other persons in the manner and on the grounds provided by the legislation of the Russian Federation, the Charter «Prisyazhnyuk’s Group. Investment Management» CJSC and local regulations, and labor contracts.