ANTI-CORRUPTION PROGRAM OF "WISE IT" LLC

Preamble

Through this Anti-Corruption Program, the Limited Liability Company “Wise IT” (hereinafter referred to as the “Legal Entity”) declares that its employees, officials, managers, and founders (participants) in their internal activities, as well as in relationships with business partners, state authorities, and local self-government bodies, will adhere to the principle of “zero tolerance” for any manifestations of corruption and will take all legally prescribed measures to prevent, detect, and combat corruption and related practices.

I. General Provisions

The Anti-Corruption Program is a set of rules, standards, and procedures aimed at detecting, combating, and preventing corruption in the activities of the Legal Entity.
The Anti-Corruption Program establishes standards and requirements not lower than those prescribed by the Law of Ukraine “On Prevention of Corruption” (hereinafter referred to as the “Law”) and the Model Anti-Corruption Program approved by the decision of the National Anti-Corruption Agency.
Terms in the Anti-Corruption Program are used in the meanings provided by the Law.
The Anti-Corruption Program is approved by the order of the Legal Entity’s manager after discussions with its employees and officials.
The text of the Anti-Corruption Program is always publicly available to the employees, officials of the Legal Entity, and its business partners.

II. Scope of Application and Persons Responsible for the Implementation of the Anti-Corruption Program

The Anti-Corruption Program is mandatory for all employees of the Legal Entity, including officials at all levels, managers, founders (participants), as well as for all business entities (branches, subdivisions, subsidiaries) under its control.
The Anti-Corruption Program also applies to the Legal Entity in its relations with business partners, including state authorities and local self-government bodies.
The following persons are responsible for the implementation of the Anti-Corruption Program within their authority:
1. Founders (participants) of the Legal Entity;
2. Manager of the Legal Entity;
3. Official responsible for the implementation of the Anti-Corruption Program (hereinafter referred to as the “Authorized Person”), whose legal status is determined by the Law and the Anti-Corruption Program;
4. Officials at all levels and other employees of the Legal Entity.

III. Anti-Corruption Measures in the Activities of the Legal Entity

List of Anti-Corruption Measures in the Activities of the Legal Entity
1. The Legal Entity ensures the development and implementation of measures that are necessary and sufficient to prevent, detect, and combat corruption in its activities.
2. Anti-corruption measures include:
  1. Regular assessment of corruption risks in the activities of the Legal Entity;
  2. Anti-corruption standards and procedures in the operations of the Legal Entity.
3. The main anti-corruption standards and procedures for the Legal Entity are:
  1. Familiarizing new employees with the content of the Anti-Corruption Program, holding training sessions on preventing and combating corruption;
  2. Anti-corruption checks of business partners;
  3. Provisions for mandatory compliance with the Anti-Corruption Program;
  4. Criteria for selecting business partners of the Legal Entity;
  5. Restrictions on political party support and charitable activities;
  6. Mechanism for reporting violations of the Anti-Corruption Program or related corruption offenses, including confidentiality and protection of whistleblowers;
  7. Functions related to preventing corruption, performed by the Authorized Person and employees;
  8. Procedure for handling whistleblower reports, including internal investigations and disciplinary actions;
  9. Professional ethics standards, employee duties, and prohibitions;
  10. Mechanisms for preventing and resolving conflicts of interest;
  11. Restrictions on gifts;
  12. Monitoring and control to ensure compliance with the Anti-Corruption Program.
Periodic Assessment of Corruption Risks in the Legal Entity’s Activities
1. The Legal Entity conducts an internal assessment of corruption risks in its activities at least once a year.
2. A corruption risk is the reasonable likelihood of a corruption or related offense occurring or the violation of the Anti-Corruption Program.
3. The assessment of corruption risks is conducted by the Corruption Risk Assessment Committee (hereinafter referred to as the “Committee”).

The procedure of activity and composition of the commission are approved by the manager.

The commission includes the Authorized Person (Chairperson of the Commission), heads of the structural divisions of the Legal Entity, as well as other employees designated by the manager in agreement with the Authorized Person.

During the assessment of corruption risks, at the initiative of the Authorized Person, other employees of the Legal Entity, as well as independent experts or specialists, may be involved in the work of the commission without being included in its composition.

The Authorized Person, to avoid conflicts of interest or bias in the commission’s work, takes into account the scope of the members’ job responsibilities within the Legal Entity when assigning functions among the commission members.

4. The purpose of the commission’s activity is to prevent, detect, and eliminate corruption risks in the activities of the founders (participants), managers, and employees of the Legal Entity.

5. Corruption risks in the activities of the Legal Entity are divided into internal and external.

Internal corruption risks are identified in the organizational and managerial, financial, economic, personnel, and legal procedures of the Legal Entity’s activities.

External corruption risks are identified in the activities of business partners, including state authorities and local self-government bodies with which the Legal Entity has business relations.

6. As a result of identifying corruption risks, the commission, in accordance with its procedure, carries out their determination and description, classification by categories and types.

7. As a result of the assessment of corruption risks in the activities of the Legal Entity, the commission prepares a written report, which is signed by the members of the commission.

The report is prepared in the form and structure defined by the commission’s operating procedure.

The report on the results of the corruption risk assessment is submitted to the manager, the founders (participants) of the Legal Entity and should include:

Identified corruption risks, as well as the causes that give rise to them and the conditions that facilitate them;
1. An assessment of the detected corruption risks;
1. Proposals for measures to prevent, eliminate (reduce) the level of the identified corruption risks.

The text of the report is made available for the employees of the Legal Entity, and may also be published on the website of the Legal Entity (if available).

8. If during the assessment of corruption risks, the Authorized Person detects a violation of the Anti-Corruption Program or the commission of a corruption-related offense, they initiate the issue of conducting an internal investigation in accordance with Section XV of the Anti-Corruption Program.

9. The Legal Entity must undergo an external assessment of corruption risks at least once every three years, conducted by organizations that provide audit, legal, or consulting services, or independent experts.

10. Based on the processing of the internal and/or external corruption risk assessment report, the manager and the founders (participants) take the necessary measures to prevent, detect, and combat corruption in the activities of the Legal Entity, including by changing the existing anti-corruption standards and procedures.

3. Description of Anti-Corruption Standards and Procedures for the Activities of the Legal Entity

To establish an appropriate level of anti-corruption culture, the Authorized Person will conduct mandatory introductory briefings for new employees, as well as for other persons acting on behalf of the Legal Entity, regarding the provisions of the Law, the Anti-Corruption Program, and related documents.
Provisions on the mandatory compliance with the Anti-Corruption Program are included in the internal labor regulations of the Legal Entity, the regulations of structural divisions, all labor contracts, and may also be included in contracts concluded by the Legal Entity.
Sample forms of anti-corruption clauses are developed by the Authorized Person, taking into account the areas of activity of the Legal Entity.
Business partners of the Legal Entity are selected based on criteria that focus on transparency, competitiveness, the quality of goods, works, and services, and reliability.
The criteria and procedures for selecting business partners for different areas of the Legal Entity’s activity are developed by the Authorized Person and approved by the manager.
The Authorized Person conducts an anti-corruption check of current or potential business partners of the Legal Entity to assess the presence of corruption risks. The Authorized Person checks whether the business partner has a reputation as an entity whose activities are related to corruption (even in the absence of relevant judicial decisions) and whether the business partner will be used as an intermediary for transferring improper benefits to third parties (or receiving improper benefits from third parties).
The anti-corruption check is conducted in accordance with the requirements of the Anti-Corruption Program and the standards for various areas of the Legal Entity’s activities, developed and approved by the Authorized Person. The materials of the check are kept for no less than 5 years.
Following the anti-corruption check of a business partner, the Authorized Person prepares a written recommendation for the manager.
In the case of a negative recommendation, the manager must make a reasoned decision regarding the continuation or initiation of business relations with such a business partner.
The Legal Entity (in the absence of legislative prohibitions) may make contributions to support political parties and engage in charitable activities only after the Authorized Person has concluded that there are no corruption risks.
The Authorized Person must make the conclusion within 10 (ten) working days after receiving all documents related to these contributions or charitable activities and send it to the manager.
The Legal Entity’s charitable activities should, as a general rule (in the absence of legislative prohibitions), be conducted only through charitable organizations in accordance with the law.
Charitable activities of the Legal Entity are not allowed if:
1. The activity is a condition for entering into any contract, making a decision by a government authority or local self-government body, or is conducted to gain an advantage in business activities;
2. A business partner or government authority or local self-government body insists on carrying out specific charitable activities through a particular charitable organization.

The Authorized Person keeps a register of the Legal Entity’s contributions to support political parties and charitable activities. The data in this register is kept for no less than 5 years.
The procedure for maintaining this register is approved by the manager, following the proposal of the Authorized Person.

To report violations of the Anti-Corruption Program or the commission of corruption-related offenses, the Authorized Person places relevant information on informational boards within the Legal Entity’s premises and on its official website (if available). This information should include:
- Phone number for reporting: +38 (066) 498 84 45;
- Email address for reporting: roman.filobok@wiseit.com.ua;
- Working hours for receiving oral and written reports: 09:00 – 18:00.

The Authorized Person develops a standard form for reporting.
The Authorized Person maintains a register of reports on violations of the Anti-Corruption Program or signs of corruption-related offenses. The procedure for maintaining this register is approved by the manager following the proposal of the Authorized Person.
The deadlines and procedure for considering reports on violations of the Anti-Corruption Program or corruption-related offenses are established in a provision approved by the manager, following the proposal of the Authorized Person.

IV. Professional Ethics Standards for Employees of the Legal Entity

Employees of the Legal Entity, in the course of performing their functional duties, must strictly adhere to generally accepted ethical norms of behavior or the requirements of the Legal Entity’s code of ethics (if available).
Employees of the Legal Entity must treat the political views, ideological, and religious beliefs of others with tolerance and respect, and must not use their authority for the benefit of political parties and/or politicians.
Employees of the Legal Entity act objectively, regardless of personal interests, personal attitudes toward any individuals, political views, ideological, religious, or other personal beliefs or convictions.
Employees of the Legal Entity must diligently, competently, timely, effectively, and responsibly perform their functional duties, decisions, and instructions of the bodies and officials to whom they report, are accountable to, or under their control, and must avoid abuse and inefficient use of the Legal Entity’s funds and property.
Employees of the Legal Entity must not disclose or otherwise use confidential information they become aware of in the course of performing their duties, except as required by law.
Employees of the Legal Entity, regardless of their personal interests, must refrain from carrying out decisions or instructions from the management of the Legal Entity if such decisions or instructions pose a threat to the legally protected rights, freedoms, or interests of individual citizens, legal entities, state or public interests, or if they contradict the law.
Employees of the Legal Entity must independently assess the legality of decisions or instructions provided by management and the possible harm that could be caused by carrying out such decisions or instructions.
In the event of receiving decisions or instructions which an employee of the Legal Entity considers illegal or posing a threat to the legally protected rights, freedoms, or interests of individual citizens, legal entities, state or public interests, the employee must immediately report this in writing to their direct supervisor, the manager of the Legal Entity, or its founders (participants) and the Authorized Person.

V. Rights and Responsibilities of Founders (Participants) and Employees (Other than the Authorized Person) of the Legal Entity

Founders (participants), the manager, employees, and other persons acting on behalf of the Legal Entity have the right to:
1. Provide suggestions for improving the Anti-Corruption Program;
2. Seek consultations from the Authorized Person regarding the implementation of the Anti-Corruption Program and clarifications on its provisions.
Founders (participants), the manager, and employees of the Legal Entity must:
1. Comply with the relevant requirements of the Law, the Anti-Corruption Program, and related internal documents, as well as ensure the practical implementation of the Anti-Corruption Program;
2. Perform their duties with due consideration for the interests of the Legal Entity;
3. Promptly inform the Authorized Person, the manager, or the founders (participants) of the Legal Entity about violations of the Anti-Corruption Program (or any instances of encouraging such violations), commission of corruption or corruption-related offenses by other employees of the Legal Entity or other individuals or legal entities with which the Legal Entity has or plans to establish business relations;
4. Promptly inform, in the manner defined by the Anti-Corruption Program, about the emergence of a real or potential conflict of interest;
5. Refrain from behavior that could be perceived as a readiness to commit a corruption-related offense in connection with the activities of the Legal Entity;
6. Not engage in or participate in corruption-related offenses related to the activities of the Legal Entity.
Employees and the manager of the Legal Entity are prohibited from:
1. Using their official powers or position, and associated opportunities, to obtain unlawful benefits for themselves or others;
2. Using any property or funds of the Legal Entity for private interests;
3. Demanding or receiving any material or non-material benefits (for themselves or close relatives) in connection with the performance of their official duties, not provided for in the labor or other contract between them and the Legal Entity;
4. Organizing, mediating, or personally conducting any cash or non-cash payments or settlements with the Legal Entity’s business partners, if such payments or settlements are not provided for by applicable law;
5. Directly or indirectly influencing the decisions of employees of the Legal Entity to obtain any material or non-material benefit for themselves or close relatives, not provided for in the labor or other contract between them and the Legal Entity;
6. Engaging in any actions that directly or indirectly incite other employees, the manager of the Legal Entity, to violate the requirements of the Law or the Anti-Corruption Program.
After dismissal or any other cessation of cooperation with the Legal Entity, an individual is prohibited from disclosing or using in any other way for their own interests any information (confidential) that became known to them in connection with the performance of their duties or contractual obligations, except in cases established by law.
Demanding, requesting, or accepting gifts for oneself or third parties from legal or natural persons by employees, the manager of the Legal Entity (directly or through others) in connection with the performance of their duties or position and associated opportunities is prohibited.
Employees and the manager may accept gifts that are in line with generally accepted ideas of hospitality (for example, gifts in the form of souvenirs, food and drink, invitations to entertainment events, reimbursement of transportation costs and accommodation), except in cases provided for in paragraph 5 of this section, if the value of such gifts does not exceed 2 (two) minimum wages established on the day the gift is received, in a single instance.
The restriction on the value of gifts does not apply to gifts that:

Are given by close relatives;
Are received as publicly available discounts on goods, services, or public wins, prizes, bonuses.

In case a gift is discovered that is prohibited to accept, or if a gift proposal is received, employees or the manager of the Legal Entity must immediately, but no later than one working day, take the following actions:

Refuse the offer;
If possible, identify the person who made the offer;
If possible, involve witnesses, including employees of the Legal Entity;
Report the offer to the Authorized Person and the immediate supervisor (if any) or the manager of the Legal Entity.

A report is prepared regarding the discovery of property that may be an unlawful benefit or a gift, which is signed by the person who discovered the unlawful benefit or gift and the Authorized Person or their immediate supervisor or the manager of the Legal Entity.
If the property or gift is discovered by a person who is the manager of the Legal Entity or the Authorized Person, the act of discovering such property is signed by this person or a person authorized to perform the manager’s duties in their absence.

Employees, the manager, and persons acting on behalf of the Legal Entity must refrain from offering gifts to government officials, members of the Ukrainian Parliament, local council deputies, their close relatives, actual or potential business partners, their employees or representatives, or engaging in any other behavior that may be perceived as a readiness to commit a corruption-related offense in connection with the activities of the Legal Entity.
Gifts may be allowed when they correspond to generally accepted ideas of hospitality and their value does not exceed the amounts set by law.
The overall policy of the Legal Entity regarding offering gifts on behalf of the Legal Entity within the framework of generally accepted hospitality standards is determined by the manager, taking into account legislative requirements.
For each case of offering or receiving a gift within the generally accepted ideas of hospitality, employees and the manager of the Legal Entity must report it in writing to the Authorized Person within one working day, using the established form.

VI. Rights and Duties of the Authorized Person and Subordinate Employees (if any)

The Authorized Person of the Legal Entity is appointed by the founders (participants) or the manager in accordance with labor legislation and the founding documents of the Legal Entity.
The Authorized Person can be an individual who, due to their professional and moral qualities, level of expertise, and health status, is capable of performing the relevant duties.
A person cannot be appointed to the position of Authorized Person if there are circumstances defined in Part 3 of Article 64 of the Law.
The position of Authorized Person is incompatible with positions listed in Item 1 of Part 1 of Article 3 of the Law, as well as any other activity that creates a real or potential conflict of interest with the activities of the Legal Entity.
If circumstances of incompatibility arise, the Authorized Person must notify the manager of the Legal Entity within two days from the occurrence of such circumstances and submit a statement to terminate the employment contract on their own initiative.
The Authorized Person may be dismissed early in the cases stipulated by Part 5 of Article 64 of the Law.
The Authorized Person can be dismissed from the position by the initiative of the manager of the Legal Entity or its founders (participants), subject to the consent of the National Anti-Corruption Agency. The procedure for granting such consent is approved by the decision of the National Anti-Corruption Agency dated October 7, 2016, No. 74, registered with the Ministry of Justice of Ukraine on November 28, 2016, No. 1542/29672.
Upon the dismissal of the Authorized Person, the manager of the Legal Entity must inform the National Anti-Corruption Agency in writing within two working days and ensure the prompt submission of a new candidate for the position.
The primary tasks of the Authorized Person are the preparation, implementation, and control over the measures for preventing, counteracting, and detecting corruption within the Legal Entity.
The Authorized Person performs their rights and duties directly. For carrying out their functions, the Authorized Person may involve (with the manager’s consent) other employees of the Legal Entity.
The exercise of the Authorized Person’s functions within the Legal Entity is independent. Any interference in the activities of the Authorized Person by employees, founders (participants), managers, business partners of the Legal Entity, or other persons is prohibited.
The Authorized Person should not be assigned duties that do not belong to their responsibilities or go beyond the powers defined by the Law and the Anti-Corruption Program, or that restrict the exercise of their powers.
The founders (participants), the manager of the Legal Entity must:

Provide the Authorized Person with appropriate material and organizational working conditions;
Support the Authorized Person in performing the functions prescribed by the Law and the Anti-Corruption Program;
Respond promptly to written and oral appeals, suggestions, and recommendations made by the Authorized Person within the implementation of the Anti-Corruption Program;
At the initiative of the Authorized Person, send requests to government authorities, local self-government bodies, enterprises, institutions, and organizations of any ownership form to obtain relevant information and materials necessary for performing the tasks assigned to the Authorized Person.
The Authorized Person, in performing their duties, is obligated to:

Perform their functions objectively and impartially;
Organize the preparation of internal documents for the Legal Entity on the formation and implementation of the Anti-Corruption Program;
Develop and submit internal documents for the Legal Entity for approval by the manager on issues covered by the Anti-Corruption Program;
Ensure the supervision, control, and monitoring of compliance with the Law and the Anti-Corruption Program by employees and the manager of the Legal Entity;
Evaluate the results of the measures specified in the Anti-Corruption Program;
Prepare a report on the status of implementation of the Anti-Corruption Program;
Ensure cooperation with individuals who responsibly report possible violations of the Anti-Corruption Program, corruption, or related offenses;
Prepare and submit proposals to the manager regarding the plan for conducting checks on compliance with the Anti-Corruption Program;
Participate in conducting checks and internal investigations carried out under the Anti-Corruption Program;
Participate in conducting periodic assessments of corruption risks in the activities of the Legal Entity;
Ensure the creation and maintenance of registers:
– Employees of the Legal Entity who have been held accountable for violating the requirements of the Anti-Corruption Program or committing a corruption-related offense;
– Contributions made by the Legal Entity to support political parties and charitable activities;
– Anti-corruption checks carried out under the Anti-Corruption Program;
– Internal investigations and checks conducted under the Anti-Corruption Program;
– Reports of conflicts of interest and violations of the Anti-Corruption Program, as well as corruption-related offenses;
Organize and conduct anti-corruption checks on the Legal Entity’s business partners;
Ensure the confidentiality of information and protect employees who report violations of the Anti-Corruption Program, corruption-related offenses, or corruption-related offenses;
Provide explanations and consultations to the founders (participants), manager, and employees of the Legal Entity regarding the application of the Anti-Corruption Program;
Ensure public awareness of the measures taken by the Legal Entity to prevent corruption;
Cooperate with government authorities, local self-government bodies, other legal entities, non-governmental and/or international organizations on anti-corruption matters;
Organize professional development activities for employees of the Legal Entity on anti-corruption issues;
Participate in the personnel selection procedures of the Legal Entity;
Ensure interaction and coordination between the structural divisions of the Legal Entity regarding the preparation, implementation, and control over the measures of the Anti-Corruption Program;
Perform other duties prescribed by the Law, Anti-Corruption Program, employment contract.
The Authorized Person has the right to:

Receive written and oral explanations from employees, the manager of the Legal Entity regarding issues related to the functions assigned to them (including during periodic assessments of corruption risks, anti-corruption checks of business partners, checks, internal investigations, and expert reviews);
Receive information and materials from the Legal Entity’s departments (certified copies of financial, accounting, and legal documents, internal official correspondence) regarding the activities of the Legal Entity, including documents related to the conduct (or participation) in procurements of goods, works, or services, in competitions, etc.
If necessary, the Authorized Person shall be granted access to the original documents, copies of which were provided to them. In cases where making a large number of document copies is impractical, the Authorized Person may, at the decision of the department head, be provided with the original documents, which must be returned within 5 (five) working days after completing the task for which they were requested;
Receive drafts of financial, organizational, and managerial documents, contracts for review to assess corruption risks;
Access the Legal Entity’s storage and production facilities and conduct control measures there;
Access the Legal Entity’s electronic data storage and processing tools and, if necessary, request that relevant data be formalized on a certified paper medium;
Involve other employees of the Legal Entity in fulfilling their functions with the manager’s consent;
Initiate requests to government authorities, local self-government bodies, enterprises, institutions, and organizations of all ownership forms to obtain information and materials related to the activities of the Legal Entity;
Initiate questions regarding the accountability of employees and the manager, including dismissal from positions in accordance with the legislation;
Address the founders (participants), the manager on the implementation of their powers and duties according to the provisions of the Anti-Corruption Program;
Exercise other rights specified by the Law, Anti-Corruption Program, employment contract, and job description.

VII. Reporting Procedure of the Authorized Person to the Founders (Participants) of the Legal Entity

The Authorized Person prepares a report on the results of implementing the Anti-Corruption Program (hereinafter referred to as the “Report”) at least once a year, within the timelines and in the manner determined by the founders (participants) or the manager.
The Report must include information on:
1. The status of the implementation of the measures outlined in the Anti-Corruption Program;
2. The results of implementing the measures outlined in the Anti-Corruption Program;
3. Identified violations of the Law, the Anti-Corruption Program, and the measures taken to address these violations;
4. The number and results of checks and internal investigations conducted;
5. Instances of interference with the proper execution of the Authorized Person’s duties, the imposition of unreasonable restrictions on them, and any external interference in their activities;
6. Any proposals and recommendations.
If necessary, the content of the provided Report is further discussed by the Authorized Person with the founders (participants) or the manager of the Legal Entity.
The overall results of implementing the Anti-Corruption Program, as mentioned in subparagraphs 1 and 2 of paragraph 2 of this section of the Anti-Corruption Program, are made publicly available in both paper and/or electronic form, as well as on the Legal Entity’s website (if available).

VIII. Procedure for Monitoring, Controlling Compliance with the Anti-Corruption Program, and Assessing the Results of Its Measures

The Authorized Person conducts oversight and constant monitoring of the compliance of employees and the manager of the Legal Entity with the Anti-Corruption Program.
The monitoring and control of compliance with the Anti-Corruption Program are carried out by the Authorized Person in the following forms:
1. Review and response to reports of violations of the Anti-Corruption Program, commission of corruption or related offenses;
2. Conducting planned and unplanned inspections of the activities of employees of the Legal Entity regarding the implementation (realization) of the Anti-Corruption Program;
3. Conducting an examination of organizational, managerial, legal, production, and financial documents, as well as their drafts.
If, during the monitoring or control of compliance with the Anti-Corruption Program, the Authorized Person detects signs of a violation of the Anti-Corruption Program or signs of a corruption or related offense, they initiate an internal investigation in accordance with Section XV of the Anti-Corruption Program.
The Authorized Person ensures the organization of the evaluation of the results of implementing the measures outlined in the Anti-Corruption Program.
To carry out the evaluation, the Authorized Person has the right to receive relevant information in writing from employees and the manager of the Legal Entity regarding the results of implementing the corresponding measures.
The results of the evaluation are summarized by the Authorized Person in a written report, which they prepare at least once every six months and submit to the manager and founders (participants). The evaluation is conducted according to the criteria established by the Authorized Person.

IX. Conditions for Confidentiality in Reporting Violations of Anti-Corruption Requirements by Employees

Employees of the Legal Entity are guaranteed confidentiality of their reports to the founders (participants), the manager, or the Authorized Person regarding signs of violations of the Anti-Corruption Program, corruption or related offenses in the activities of other employees of the Legal Entity, and reports of instances of incitement to employees of the Legal Entity to commit corruption or related offenses.
Reports about identified signs of violations of the Anti-Corruption Program, as well as reports about incitement of employees of the Legal Entity to commit corruption or related offenses, may be made orally or in writing, through the communication channels specified in the Anti-Corruption Program. Reports may also be made by employees and officials of the Legal Entity’s business partners.
The manager ensures the round-the-clock operation of these communication channels and their protection from external interference and information leakage.
Submitting knowingly false reports is prohibited.
Reports by employees of the Legal Entity regarding signs of corruption or related offenses may be anonymous.
An anonymous report on signs of corruption or related offenses may only be considered if the information provided concerns a specific employee of the Legal Entity or its business partners and contains factual data that can be verified.
The Authorized Person is responsible for verifying the information presented in the report, and if the report concerns the actions of the Authorized Person themselves, an employee designated by the founders (participants) or the manager conducts the verification.
Any data that could identify the individual reporting the incitement to commit a corruption or related offense, or about the identification of violations of the Anti-Corruption Program, committed by employees or others, is considered confidential and protected by law.
The Authorized Person and individuals involved in the verification of the reported information are prohibited from disclosing this information.

X. Procedures for Protecting Employees Who Report Corruption or Corruption-Related Offenses

The manager and/or the Authorized Person, within their powers, ensure conditions for the protection of individuals who assist in preventing, detecting, and counteracting corruption within the Legal Entity.
Information about an employee who reports signs of violations of the Anti-Corruption Program or signs of corruption or corruption-related offenses (hereinafter referred to as the “Whistleblower”) cannot be disclosed, except in cases provided by law.
A Whistleblower cannot be dismissed or forced to resign, subjected to disciplinary action, or subjected to any other negative measures (such as transfer, reassessment, changes in working conditions, refusal to appoint to a higher position, salary reduction, etc.) or the threat of such measures due to their report on violations of anti-corruption legislation and/or the Anti-Corruption Program.
In the event of a leak of confidential information about the Whistleblower, the manager of the Legal Entity or the Authorized Person, upon the request of the employee or on their own initiative, must immediately take all necessary measures to prevent any negative consequences for the Whistleblower related to such disclosure.
Measures to protect the Whistleblower are determined by the founders (participants) or the manager, in cooperation with the Authorized Person, and are implemented with the written consent of the employee.

XI. Conflict of Interest Resolution in the Activities of Employees of the Legal Entity

Employees of the Legal Entity must, no later than the next working day from the date when they became aware or should have become aware of the existence of a real or potential conflict of interest, notify their immediate supervisor in writing, refrain from taking actions or making decisions in situations of a real conflict of interest, and take measures to resolve the real or potential conflict of interest.
If a real or potential conflict of interest arises for the manager of the Legal Entity, they must notify the Authorized Person and the founders (participants) in writing.
If a real or potential conflict of interest arises for the Authorized Person, they must notify the manager in writing.
The immediate supervisor of an employee, within two working days of receiving a notification about a real or potential conflict of interest in a subordinate, must decide how to resolve the conflict of interest and inform the employee.
The immediate supervisor, upon learning of a conflict of interest in a subordinate employee, is obligated to take legal measures to prevent and resolve the conflict of interest (including in cases where the supervisor independently identifies a conflict of interest without the employee’s notification).
The conflict of interest is resolved through one of the following measures:
1. Removing the employee from performing the task, taking actions, making decisions, or participating in decision-making;
2. Imposing additional control over the employee’s task execution, actions, or decision-making;
3. Restricting the employee’s access to certain information;
4. Revising the scope of the employee’s functional duties;
5. Transferring the employee to another position;
6. Dismissing the employee.
  The procedure for applying conflict resolution measures and their specific features for different categories of employees is established by the Authorized Person.
A decision on resolving the conflict of interest in the activities of the manager of the Legal Entity is made by the founders (participants).
Employees of the Legal Entity may independently take steps to resolve the conflict of interest by removing the relevant private interest and providing supporting documents to the immediate supervisor and the Authorized Person. The removal of the private interest must eliminate any possibility of concealing it.

XII. Procedure for Providing Clarifications and Consultations to Employees by the Authorized Person

In case of questions regarding the interpretation of certain provisions of the Anti-Corruption Program, the founders (participants), manager, and employees of the Legal Entity may contact the Authorized Person for oral or written clarification.
The essence of the request for clarification or consultation is presented directly to the Authorized Person (during the personal reception days and hours defined by the Authorized Person) or by sending a service memo or written request to their email address in any format.
The Authorized Person provides oral clarification during a personal reception or in writing—no later than three (3) working days from the date of receiving the request.
The Authorized Person may extend the review period, but not more than five (5) working days, and must inform the requesting individual in writing.
If, during the provision of clarification, the Authorized Person identifies signs of violations of the Anti-Corruption Program or signs of corruption or related offenses, they initiate a request for an internal investigation before the manager, in accordance with Section XV of the Anti-Corruption Program.

XIII. Procedure for Periodic Professional Development of Employees in the Area of Corruption Prevention and Detection in the Legal Entity

Professional development of employees of the Legal Entity in the area of corruption prevention and detection is carried out to provide basic knowledge of anti-corruption legislation, improve compliance with the Anti-Corruption Program, foster an anti-corruption culture, and promote intolerance to corruption.
Professional development is carried out according to a thematic plan-schedule for each half-year, approved by the manager of the Legal Entity and prepared by the Authorized Person.
The professional development plan should include activities for all employees of the Legal Entity as well as specific activities for the manager and/or the founders (participants) of the Legal Entity.
The topics and form of the professional development activities (seminars, lectures, workshops, training, webinars, etc.) are determined by the Authorized Person, taking into account:
1. Suggestions from the manager, founders (participants), and heads of structural divisions;
2. Results of evaluating the implementation of the Anti-Corruption Program’s measures;
3. Results of periodic assessments of corruption risks in the activities of the Legal Entity;
4. Results of internal investigations;
5. The report of the Authorized Person to the founders (participants).
The time allocated for professional development in the area of corruption prevention and detection should constitute at least 1% of the total working hours for each half-year.
The Authorized Person is responsible for keeping records of the professional development activities in the area of corruption prevention and detection, as well as monitoring attendance.

XIV. Application of Disciplinary Measures to Employees Violating the Provisions of the Anti-Corruption Program

If there is information indicating signs of employees violating the requirements of the Anti-Corruption Program, the following measures are taken:
1. An internal investigation is initiated according to the procedure specified in Section XV of the Anti-Corruption Program to confirm or deny the information about the possible violation;
2. If there is sufficient evidence based on the results of the internal investigation, the manager imposes a disciplinary penalty in accordance with the law.
Disciplinary penalties are imposed by the manager on employees of the Legal Entity in accordance with labor legislation.

XV. Procedure for Conducting Internal Investigations

If a report is received or signs of a violation of the Anti-Corruption Program by an employee of the Legal Entity or signs of a corruption or corruption-related offense by an employee are detected, the Authorized Person informs the manager, who takes the measures specified in paragraph 2 of this section.
If a report is received or signs of a violation of the Anti-Corruption Program by the manager or signs of a corruption or corruption-related offense are detected, the Authorized Person informs the founders (participants), who take the measures specified in paragraph 2 of this section.
If a report is received or signs of a corruption or corruption-related offense committed by the Authorized Person are found, the manager informs the founders (participants) of the Legal Entity and takes the measures specified in paragraph 2 of this section.
Under the conditions specified in paragraph 1 of this section, the founders (participants) and the manager are required to take the following measures:
1. Within three (3) working days, initiate an internal investigation to confirm or deny the information about the possible violation of the Anti-Corruption Program or a corruption or corruption-related offense;
2. Based on the results of the internal investigation, apply disciplinary measures to the responsible individuals if there are grounds;
3. Based on the results of the internal investigation, determine the ways to eliminate the causes and consequences of the violation, if any, and ensure measures to prevent such actions in the future;
4. If signs of a corruption or corruption-related offense are found, for which administrative or criminal liability is provided, immediately inform the authorized anti-corruption bodies.
Internal investigations are conducted only if the provided or detected information concerns specific individuals and contains factual data that can be verified.
Internal investigations are assigned by the manager and carried out by a commission. The procedure for conducting internal investigations under the Anti-Corruption Program is approved by the manager.
The commission must include the Authorized Person, except in cases where the investigation is initiated due to facts or information about violations by the Authorized Person.
The investigation period must not exceed 60 (sixty) calendar days.
Materials of internal investigations are kept in the Authorized Person’s archive for at least 5 years.
If, based on the results of the internal investigation, disciplinary measures are imposed on the Authorized Person, the National Anti-Corruption Agency must be notified in writing within two working days from the date the penalty is imposed.

XVI. Procedure for Amending the Anti-Corruption Program

The manager of the Legal Entity ensures the organization of feedback mechanisms and other internal processes aimed at maintaining and continuously improving the Anti-Corruption Program.
The content of the Anti-Corruption Program may be reviewed based on the results of:
1. The report on the assessment of corruption risks in the activities of the Legal Entity;
2. Monitoring and control over the compliance with the Anti-Corruption Program, as well as evaluating the results of the measures implemented by it;
3. Analysis of the practice of the Authorized Person performing their duties;
4. Conducting surveys, discussions, and consultations by the Authorized Person with employees, the manager, the founders (participants), and business partners of the Legal Entity regarding the improvement of the Anti-Corruption Program.
The Authorized Person, as well as the founders (participants), the manager, and employees of the Legal Entity, may propose amendments to the Anti-Corruption Program.
Proposals for amendments to the Anti-Corruption Program are submitted to the Authorized Person, who examines and systematizes them. Once a year, the Authorized Person provides the manager with a summary of the proposals received for amending the Anti-Corruption Program, along with their recommendations on whether to incorporate or reject them.
After receiving the summary of proposals from the Authorized Person, the manager initiates an open discussion of the proposed amendments with the workforce and the founders (participants).
If the founders (participants) or the Authorized Person insist on urgent amendments to the Anti-Corruption Program, the manager initiates the corresponding discussion within the shortest possible time, but no later than 10 days from the date of receiving such proposals.
If the proposals are approved by the founders (participants) and employees (the workforce) of the Legal Entity, the manager, by order, approves the corresponding amendments to the Anti-Corruption Program, which become an integral part of it.