1. Introduction

1.1 The present Anticorruption Policy (hereinafter referred to as "Policy") is the basic document of “BURINTEKH”, Ltd (hereinafter referred to as “Company”), defines key principles and requirements aimed to prevention of corruption and compliance with the norms of the anticorruption legislation of the Russian Federation by employees and other persons who can act on behalf of the Company.

1.2. The anticorruption policy is developed in accordance with:

  • The Constitution of the Russian Federation as of December 12, 1993;
  • Federal Law No. 273-FZ dated 25.12.2008 "On Corruption Control";
  • Federal Law dated 08.02.1998 No. 14-FZ "On Limited Liability Companies";
  • Law of the Republic of Bashkortostan dated 13.07.2009 N 145-z "On Corruption Control in the Republic of Bashkortostan";
  • Methodical recommendations of the Ministry of Labor and Social Protection of the Russian Federation on the development and adoption by organizations of measures to prevent and counteract corruption.

1.3. The present Policy establishes:

  • Corruption control general principles;
  • Legal and institutional basis of corruption prevention and anticorruption efforts;
  • Mitigation and (or) remediation of corruption offences.

1.4. For the purposes of the present Policy the present general definitions are used:

Corruption - abuse of official position, bribery, bribery taking, abuse of authority, commercial bribery or other unlawful use by an individual of his official position, contrary to the legitimate interests of society and the state, in order to obtain benefits in the form of money, valuables, other property or services of a property nature, other property rights for themselves or for third parties or the unlawful provision of such benefits to the said person by other individuals.

Conflict of interest, a situation in which the personal interest (direct or indirect) of the employee (representatives) affects or may affect the proper performance of official (employment) duties and in which there is or may be a conflict between the personal interest of employees (representatives) and rights and the legitimate interests of the Company, which could prejudice the rights and legitimate interests, property and (or) the business reputation of the Company's employee (representative of the Company).

2. Policy purpose

2.1. Policy purpose is to form a unified approach to corruption control activities in Company.

3. Policy objectives

3.1. The objectives of the Policy are:

  • Formation of a clear understanding among the partners, contractors, and employees of the Company of the Company's position on corruption aversion in all forms and manifestations;
  • Definition of the basic principles of corruption control in the Company;
  • Prevention of corruption and other offenses; responsibility maintaining;
  • Minimization of risks of involvement of the Company in corrupt practices;
  • Establishment of procedures and measures aimed to preventing and combating corruption in the Company.

4. Company anticorruption Policy fundamentals

4.1. The policy in the Company is based on the following fundamentals:

  • Compliance with the current legislation of the Russian Federation;
  • Personal example of leadership;
  • Personnel involvement;
  • Adequacy of anticorruption procedures to the risk of corruption;
  • Effectiveness of anticorruption procedures;
  • Consequences unavoidability;
  • Openness of the Company;
  • Constant monitoring and regular monitoring.

5. Company corruption preventive measures

5.1. Corruption preventive measures in the Company are:

  • Appointment of responsible persons for the prevention of corruption and other offenses;
  • Cooperation with law enforcement agencies in the field of combating corruption;
  • Implementation of information and educational activities for the Company's employees for corruption prevention;
  • Reception and consideration of reports on cases of declination of employees of the Company to commit corrupt offenses in the interests or on behalf of another organization, as well as cases of corruption offenses committed by employees, counterparties of the organization or other persons;
  • Development and implementation of a set of standards and procedures aimed to ensuring fair work;
  • implementation of measures to prevent and prevent corruption in cooperation with partners and counterparties;
  • Taking measures to prevent or eliminate conflicts of interest in the Company;
  • Development of local regulatory acts aimed to implementing measures to prevent and counteract corruption.

6. Governmental authority interaction

6.1. The interaction of the Company with law enforcement, controlling authorities, other state authorities, municipal authorities, their representatives, as well as with public organizations and their representatives is carried out strictly within the framework of the current legislation.

6.2. The Company does not make illegal payments in favor of the above-mentioned bodies, organizations, their representatives and other persons, including through intermediaries, including payment for rest, entertainment, transportation and other expenses, in order to obtain or retain business advantages.

7. Scope of persons subject to Policy

7.1. Main scope of persons subject to the Policy are employees of the Company who have an employment relationship with Company, regardless of the position and the functions performed, and other persons with whom the Company enters into contractual relations.

8. Persons responsible for corruption control in Company

8.1. Persons responsible for corruption control in the Company are:

  • General Director;
  • Deputies General Director for the areas of activity.

8.2.Functions, tasks, powers of responsible persons for corruption control in the Company may be determined by certain local regulatory acts of the Company.

9. Liability for nonperformance (improper performance) of Policy

9.1. Responsibilities for corruption and other offenses in the Company include: disciplinary, administrative and criminal liability measures in accordance with the legislation of the Russian Federation, corporate enforcement actions in accordance with local regulatory acts of the Company.

10. Policy modifications

10.1. The introduction of changes to the Company's Policy is carried out in the following cases:

  • Necessity to bring the provisions of the Policy in line with changes in Russian anticorruption legislation;
  • Changes in the organizational and staff or functional structure of the Company, which have a direct impact on the implementation of this Policy.

10.2. The Company's policy is communicated to all employees of the Company. Familiarization with the Policy of persons employed to the Company is carried out against signature. Provision of unhindered access for Company's employees to the text of the Policy by posting it on the official website of the Company.

10.3. Changes to this Policy are posted on the Company's official website and are mandatory for application by the Company.