Alignment of the Company’s anti-corruption measures with the Constitution of the Russian Federation, Russian legislation and other regulatory legal acts applicable to the Company.

A strict prohibition for Employees, members of governing bodies of the Company and other persons acting on behalf of or in the interests of the Company, whether directly or indirectly, personally or through any intermediary, to participate in corrupt activities.

Inevitability of punishment for Employees regardless of position, length of service or other circumstances in the event of committing corrupt offences in connection with the performance of employment duties, as well as the personal accountability of the CEO for implementing the Company’s internal anti-corruption policy.

Segregation of incompatible duties prevents the same Employee from simultaneously being assigned both process execution and control/evaluation functions, thereby minimising corruption incidents.

The key role of the Company’s management (senior executives of the Company) in fostering a culture of intolerance towards corruption and establishing an internal system for preventing and countering corruption. All senior management must publicly declare an uncompromising stance towards any form of corruption and demonstrate, observe and implement this principle in practice.

Regular monitoring of the effectiveness of implemented anti-corruption standards and procedures, as well as control over their compliance. Continuous scrutiny of the economic justification for all expenditures. Conducting corruption risk assessments.

Development and implementation of measures to reduce the likelihood of the Company, the CEO and Employees becoming involved in corrupt activities, taking into account existing corruption risks in the Company’s operations. Striving to make procedures maximally transparent, clear, feasible and reasonably proportionate to the identified risk.

Ensuring centralised management of anti-corruption efforts, with clear allocation of responsibilities and authorities in the anti-corruption process.

Conducting due diligence on counterparties and job candidates prior to deciding to commence or continue business/employment relationships, with regard to their reliability, rejection of corruption and absence of conflicts of interest.

Expectation that each Employee of the Company will prioritise the Company’s interests over personal interests when performing duties and will avoid situations that are or may be regarded as conflicts of interest.

Ensuring Employees’ awareness of anti-corruption legislation and their active participation in developing and implementing anti-corruption standards and procedures.