Excerpt from the Policy for Prevention and Combating Corruption of the Intelligent Business Management Systems LLC was approved by the General Meeting of the Company's participants (Minutes no. n/n of 05.02.2021) and the General Director of ISUB LLC (Order No. P-398/2021 of 05.02.2021).)
The commitment of the Intellectual Business Management Systems Limited Liability Company (hereinafter referred to as the Company) to the law and high ethical standards in business relations provides contributes to strengthening its credibility among other companies and clients. At the same time, the Company's reputation may serve to some extent as a protection against corruption attacks by unscrupulous officials of other companies and public authorities: the latter may refrain from offering or extorting illegal remuneration, since they will know that such an offer will be rejected.
The anti-corruption prevention and counteraction policy (hereinafter referred to as the Policy, Anti-Corruption Policy) is a system of interrelated principles, procedures and specific measures aimed at preventing and suppressing corruption offenses in the Company's activities and the main approaches to be applied within the Group.
The anti-corruption policy is developed in compliance with the requirements of Russian and international legislation, as well as taking into account the methodology, principles and best international practices. The fundamental normative legal act in the field of combating corruption is Federal Law No. 273-FZ of December 25, 2008 "On Combating Corruption "(hereinafter referred to as the Federal Law "On Combating Corruption").
Goals and objectives of the implementation of Anti-corruption policy in the organization
This Policy is aimed at forming a uniform understanding of the essence of corruption actions, their forms and exercise among all employees and managers of the Company in order to prevent and suppress any situations and actions that, including potentially, may violate the requirements of the Russian anti-corruption legislation and other applicable norms of international law.
The main objectives of the anti-corruption system in the Company are:
- establish principles and rules for combating corruption in the Company;
- create effective mechanisms, procedures, control and other measures aimed at combating corruption and minimizing the risks of involvement of the Company/Group members, as well as their employees in corruption activities;
- build a culture of ethical behavior and intolerance to all manifestations of corruption, including a single standard of anti-corruption behavior among the Company's employees;
- integrate anti-corruption principles into strategic and operational management at all levels of the Company's activities;
- form a common understanding of the principles of this Policy among the Company's employees, customers, counterparties, participants, investors and other persons;
- inform the Company's management bodies about corruption offenses and measures taken to counteract corruption;
- apply measures establishing penalties for corruption offenses.
Concepts and definitions used in the Policy
Corruption actions, in the context of this Policy, are:
- giving a bribe or mediation in giving a bribe, that is, providing or promising to provide any financial or other benefit/advantage with the intent to induce any person to perform his official duties improperly, that is, on more favorable terms for the giver and (or) in violation of the rules and procedures established by the legislation of the Russian Federation and/or internal regulatory documents of the Company;
- receiving a bribe or mediation in receiving a bribe, that is, receiving or agreeing to receive any financial or other benefit / advantage for performing their official duties improperly, that is, on more favorable terms for the giver and / or in violation of the rules and procedures established by the legislation of the Russian Federation and/or internal regulatory documents of the Company;
- commercial bribery, that is, the illegal transfer of the person performing official functions in Society, money, securities, other property, providing a property-related services, all other property rights for acts/omissions in relation to his/her official position in the interests of the giver;
- bribery of public officials, i.e. providing or promising to provide them any financial or other benefit/advantage in order to influence the performance of their official responsibilities and job functions in order to gain / retain business or provide competitive or other advantages for Society;
- use by members of the management bodies, employees of the Company for themselves or for the benefit of third parties of opportunities related to their official position and / or official power to obtain financial or other benefits / advantages not stipulated by the legislation of the Russian Federation and / or internal regulatory documents of the Company;
- other illegal use of one's official position contrary to the legitimate interests of the Company, society, or the state in order to obtain financial or other benefits/advantages.
Employees of the Company and its Group are prohibited from performing any of the actions listed above.
Basic principles of the organization's anti-corruption activities
The system of anti-corruption measures in the Company is based on the following key principles:
Compliance of the organization's policy with the current legislation and generally accepted norms
Compliance of the implemented anti-corruption measures with the Constitution of the Russian Federation, international agreements concluded by the Russian Federation, the legislation of the Russian Federation, other regulatory legal acts applicable to the Company, and international legislation.
Personal example of top managers
The key role of the Company's management in building a culture of intolerance to corruption and in creating an internal system for preventing and combating corruption.
Awareness of employees about the provisions of anti-corruption legislation and their active participation in the development and implementation of anti-corruption standards and procedures.
Commensurability of anti-corruption procedures to the risk of corruption
The development and implementation of a complex of measures to reduce the likelihood of involvement of the Company, its managers and employees in corruption activities is realized taking into account the existing corruption risks in the Company's activities.
Effectiveness of anti-corruption procedures
The use of such anti-corruption measures in the Company, which have a low cost, provide for easy implementation and bring significant results.
Responsibility and the inevitability of punishment
The inevitability of punishment for all employees, regardless of their position, work experience and other conditions, in case they commit corruption offenses in connection with the performance of their job functions, as well as the personal responsibility of the Company's management for the implementation of the internal anti-corruption policy.
Openness and transparency
Informing contractors, partners and the public about the Company's anti-corruption standards for conducting business.
Constant control and regular monitoring
Regular monitoring of the effectiveness of the implemented anti-corruption standards and procedures, as well as monitoring their implementation.
Principal measures and directions of work for prevention and combating corruption
Measures to prevent corruption taken in the Company include:
- assigning of departments or officials responsible for prevention of corruption and other offences;
- cooperation of the Company with law enforcement agencies;
- development and implementation of standards and procedures aimed at ensuring the Company's integrity;
- adoption of the Code of Corporate Ethics and Official Conduct of the Company's employees;
- prevention and settlement of conflicts of interest;
- analysis of the main causes of misconduct in order to respond in a timely and appropriate manner;
- avoiding informal reporting and the use of forged documents;
- conducting anti-corruption due diligence of the target company before a merger or takeover.
The Company's anti-corruption policy is aimed at implementing these measures.
Operating the Hotline and reporting
The Hotline is a safe and confidential information channel for Company employees and other third parties, including customers and counterparties, to provide information on intentions or facts of corrupt practices with regard to the Company and/or its employees, customers, counterparties, allowing, inter alia, to transmit information anonymously.
The Company guarantees the principle of confidentiality to all whistleblowers and that provided info will be investigated within the timeframe set by the Company and no sanctions (dismissal, demotion, loss of bonus, etc.) will be imposed if an employee reports an alleged case of corruption, including if the facts stated in the report were not confirmed during the investigation. However, if such a report is made with malicious intent, as knowingly false, e.g. to defame or obtain any preferences or to avoid liability, such employee will be subject to sanctions in accordance with the provisions of this Policy and applicable law.
The Company provides the following channels of information :
Anti-corruption measures during the interaction with contractors
The requirements of this Policy shall be taken into account when the Company establishes contractual and other business relationships with individuals and legal entities. The Company expects counterparties, Company officials, members of management bodies and employees to comply with the relevant anti-corruption obligations set forth in the Company's contracts with them, job descriptions or those directly arising from applicable laws, national laws of the country of registration and/or operation of the said persons and international law.
The Company makes reasonable and possible efforts under the circumstances to minimize the risk of violating applicable anti-corruption laws when establishing business relationships with customers and counterparties who have been or may be involved in corrupt practices. In this regard, the Company:
- conducts due diligence on potential counterparties, their shareholders/participants and beneficial owners, including their tolerance of corruption, and the existence of anti-corruption regulations and procedures;
- inform potential contractors of the Company's anti-corruption principles and requirements set out in this Policy, including relevant anti-corruption clauses in agreements/contracts made by the Company with the said persons, as well as by posting information on the Company's external website, in the Anti-Corruption section;
- takes into account the willingness of potential counterparties to comply with anti-corruption principles and requirements and to provide mutual assistance to prevent corruption offences in their activities.
This Policy may be amended in the event of changes in the laws of the Russian Federation or applicable international laws, and in the light of new trends in global and Russian corporate conduct practices.
The Company, by posting this Policy or certain provisions thereof in in free access on the Company's official website, openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all Company employees, counterparties and other third parties, and promotes an anti-corruption culture in society and among Company employees through information and education.
The Company shall, on a reciprocal basis, cooperate in the field of anti-corruption with state and regulatory authorities, as well as with societies and associations of which the Company is a member, partners and customers in order to:
- identify persons suspected (accused) of committing corruption offences, their whereabouts, as well as the whereabouts of other persons involved in corruption offences;
- trace property obtained through the commission of corruption offences or serving as a vehicle for the commission of such offences;
- exchange information on anti-corruption issues;
- coordinate activities to prevent and combat corruption.