Anti-corruption policy

General working conditions 

 APPROVED 

 Managing Director of NPO Uran 

 Cherepkova N. And. 29.07.2019 year

ANTICORRUPTION POLICY

NPO Uran

1.1. This regulation has been developed in accordance with Federal law No. 273-FZ of 25.12.2008 "on anti-corruption" in order to protect the rights and freedoms of citizens, ensure law and order and public safety, defines the tasks, basic principles of anti-corruption and measures to prevent corruption offenses, compliance with anti-corruption legislation by management, employees and other persons who may act on behalf of SPE URANUS (hereinafter-the Company). 

1.2. anti-Corruption measures of SPE URANUS are aimed at: - prevention of corruption, including identification and subsequent elimination of the causes of corruption (prevention of corruption); - detection, prevention, suppression, disclosure and investigation of corruption offenses (fight against corruption); — minimization and (or) elimination of consequences of corruption offenses. 

1.3. All employees of the Company must be guided by this anti-Corruption policy and strictly comply with its principles and requirements.  

BASIC CONCEPT 

2.1. For the purposes of this regulation, the following basic concepts are used: anti — Corruption policy-the activities of SPE URANUS aimed at creating an effective system of anti-corruption. Corruption – abuse of official position, bribery, receiving a bribe, abuse of authority, commercial bribery or other illegal use of his official position contrary to legitimate interests of society and the state in order to obtain benefits in the form of money, valuables, other property or services of property character, other property rights for itself or for third parties or illegal provision of such benefits specified person other individuals. Conflict of interest – a situation in which personal interest (direct or indirect) employee affects or may affect the proper performance of his official duties and which arises or may arise a contradiction between personal interest of the employee and the rights and legitimate interests of the society that could lead to harm to the rights and legitimate interests, property and (or) the company's business reputation. Corruption manifestations – actions (omissions) of the Company's employees that contain signs of corruption or contribute to its Commission. Corruption offense – an act that has signs of corruption, for which a regulatory legal act provides for civil, disciplinary, administrative or criminal liability. Corruption factor – a phenomenon or set of phenomena that generate corruption offenses or contribute to their spread. Prevention of corruption – activities of SPE URANUS on anti-corruption policy aimed at identifying, studying, limiting or eliminating the phenomena that generate corruption offenses or contribute to their spread. 

GOALS AND OBJECTIVES OF THE ANTI-CORRUPTION POLICY 

3.1. The policy reflects the desire of SPE URANUS and its management to comply with high ethical standards and principles of open and honest business conduct, as well as maintaining a proper reputation. 

3.2. The purpose of the anticorruption policy – development and implementation of versatile and consecutive measures for prevention, elimination (minimization) of causes and conditions generating corruption, forming of the anticorruption consciousness, characterized by intolerance of employees, customers, contractors, authorities for corrupt practices. 

3.3. The objectives of the company's anti-corruption policy are — - formation of a uniform understanding of the company's policy on non-acceptance of corruption in any form and manifestations; - minimizing the risk of involvement of the Company's management and employees, regardless of their position, in corruption activities; - explaining to employees the main requirements of the anti-corruption legislation of the Russian Federation; - establishing the duties of employees to know and comply with the principles and requirements of this Policy, key anti-corruption legislation, as well as measures to prevent corruption. 

SCOPE AND RESPONSIBILITIES 

4.1. All employees of SPE URANUS, regardless of their position and functions, must be guided by this Policy and strictly comply with its principles and requirements. 

4.2. The management of SPE URANUS is responsible for organizing all activities aimed at implementing the principles and requirements of this Regulation, including the appointment of persons responsible for the development of anti-corruption measures, their implementation and control. 

4.3. The principles and requirements of this Regulation apply to contractors and representatives of SPE URANUS , as well as to other persons in cases when the corresponding obligations are stipulated in contracts with them, in their internal documents, or directly follow from the law.

ANTICORRUPTION LEGISLATION 

5.1. SPE URANUS and all employees must comply with Russian anti-corruption law established, including the Criminal code, Code on administrative offences, Federal law "On combating corruption" and other normative acts, the basic requirements of which are the prohibition of bribery, the prohibition of bribery, the prohibition of bribery and the prohibition of mediation in bribery.

5.2. The main principles of the Federal law "on anti-corruption": prohibition of giving bribes, i.e. providing or promising to provide any financial or other benefit/advantage with the intent to induce any person to perform their official duties improperly; prohibition of receiving bribes, i.e. receiving or agreeing to receive any financial or other benefit/advantage for performing their official duties improperly; prohibition of bribing public officials, i.e. providing or promising to provide (directly or through third parties) any financial or other benefit /advantage to a public official in order to influence the performance of his official duties improperly. 

5.3. In view of the above, all employees are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, to participate in corrupt actions, offer, give, promise, ask for or receive bribes. 

KEY PRINCIPLES OF ANTI-CORRUPTION POLICY 

6.1. The principle of non-acceptance of corruption in any form and manifestations in the conduct of daily activities, including in interaction with contractors, representatives of government bodies, political parties, their employees and other persons, is enshrined in SPE URANUS. 

6.2. The key principles of the anti-corruption policy are: the Principle of compliance of the anti-corruption policy with the current legislation of the Russian Federation 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 and other regulatory legal acts applicable to the company. The principle of the personal example of leadership. The key role of the company's management in forming a culture of intolerance to corruption and in creating a system for preventing and combating corruption. The principle of employee engagement. Awareness of employees about the provisions of the anti-corruption legislation of the Russian Federation, their active participation in the formation and implementation of anti-corruption standards and procedures. The principle of adequacy of anti-corruption procedures. Identification and assessment on a periodic basis of corruption risks specific to the company's activities, implementation of measures to prevent corruption that reasonably meet the identified risks. The principle of responsibility and inevitability of punishment. The certainty of punishment for all without an exception of employees in the event they commit a corruption offence in connection with the performance of duties and personal responsibility for the implementation of internal anti-corruption policy. The principle of open business. Informing contractors and other persons about the company's anti-corruption business standards. The principle of control and monitoring. Monitoring the effectiveness of implemented anti-corruption standards and procedures, as well as monitoring their implementation. 

DIRECTIONS OF THE COMPANY'S ANTI-CORRUPTION POLICY 

7.1. The role of management. The Company's management and officials should form an ethical standard of non-tolerance towards any forms and manifestations of corruption at all levels, setting an example by their behavior and familiarizing all employees with the anti-corruption policy. 

7.2. Prohibition of corruption. Employees of the Company are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, from participating in corrupt actions, or from receiving remuneration from individuals and legal entities in connection with the performance of their work duties (gifts, monetary remuneration, services, entertainment, recreation, transportation expenses, and other remuneration). 

7.3. Adequate anti-corruption procedures and risk assessment. The company systematically identifies and assesses the possibility of corruption risks specific to its activities. Conducts measures to prevent corruption that reasonably meet the identified risks and monitors their compliance. 

7.4. Duties of the company's employees: - to be honest and decent in the business relations, to refrain from any dishonest ways of doing business; -not to use for personal purposes official position, confidential information, tangible and intangible assets of the Company; -in their activities, do not allow illegal actions, or actions that may raise suspicions about their legality and ethics; -refrain from committing and (or) participating in the Commission of corruption offenses in the interests of or on behalf of the Company; -refrain from behavior that may be interpreted by others as a willingness to commit or participate in the Commission of a corruption offense; -immediately inform the direct Manager or the management of the Company about cases of inducement of the employee to commit corruption offenses; -immediately inform the direct Manager or management of the Company about information that has become known to the employee about cases of corruption offenses committed by other employees, contractors of the organization or other persons. E-mail address for information: security@spe-uranus.com; -notify the management of the Company, the Prosecutor's office or other state bodies of any persons who have applied to it in order to incite them to commit corruption offenses; -inform the Manager or his immediate supervisor about the possibility of a conflict of interest that may arise or that the employee has. 

7.5. Managing Conflicts of interest. 

7.5.1. The company takes measures to prevent conflicts of interest. The measures are aimed at excluding the possibility of obtaining material and (or) personal benefits for employees as a result of using their official position due to the fact that they (their family members, close relatives) have rights that provide such an opportunity. 

7.5.2. The company strives to prevent and resolve pre conflict situations among employees in a timely manner 

7.5.3. The company adheres to the following principles for managing conflicts of interest: 

-mandatory disclosure of information about a real or potential conflict of interest 

-individual consideration and assessment of each conflict of interest and its resolution; 

-confidentiality of the conflict of interest disclosure and resolution process;

 -compliance with the interests of the Company and the employee in the settlement of conflicts of interests; 

-protection of an employee from prosecution in connection with a report of a conflict of interest that was promptly disclosed by the employee and settled by the Company. 

7.6. Gifts and representation expenses. 

7.6.1. Gifts that employee may provide to other persons and organizations on behalf of SPE URANUS, gifts that employees may receive from other persons and organizations in connection with their activities in the Company, as well as representation expenses, including 

-expenses of the Company's employees for business hospitality must simultaneously meet the following criteria: 

-be directly related to the legitimate goals of SPE URANUS or national holidays (New Year, March 8, February 23, etc.), memorable dates, anniversaries — - be reasonable, proportionate and not be luxury items; the cost of the gift can not exceed 3 000,00 (three thousand) rubles (paragraph 2 of article 575 of the civil code of the Russian Federation); 

- do not represent a hidden remuneration for a service, action, omission, granting of rights, making a certain decision on a transaction, etc., or an attempt to influence the recipient for any other illegal or unethical purpose; 

- do not create a risk to the reputation of SPE URANUS, employees and other persons in the event of disclosure of information about gifts or representative expenses; 

-not contradict the principles and requirements of this Regulation, the code of business ethics, other internal documents of the Company and the applicable legislation. 

7.6.2. Gifts in the form of cash are prohibited 

7.7. Participation in charitable activities. SPE URANUS can decide to participate in charity events aimed at creating the image of the Society as a socially responsible business. The company does not Finance charitable projects in order to obtain commercial advantages in specific projects of the Company. 

7.8. Participation in political activities 

7.8.1. The company does not Finance political parties, organizations or movements in order to obtain advantages in commercial activities. 

7.8.2. Employees of the Company have the right to participate on their own behalf in political parties, public organizations and movements, public funds, and other non-profit organizations established in accordance with the current legislation of the Russian Federation. 

7.8.3. Employees of the Company are independently responsible in accordance with the current legislation of the Russian Federation for participation in public organizations. 

7.9. Interaction with civil servants 

7.9.1. The company does not independently or through its employees pay any expenses (monetary remuneration, loans, services, entertainment, recreation, transport expenses and other remuneration) for public servants and their close relatives (or in their interests) in order to obtain or maintain an advantage in commercial activities. 

7.9.2. Employees of the Company are independently responsible for corruption when interacting independently with civil servants in accordance with the current legislation of the Russian Federation 

7.10. Interaction with employees 

7.10.1. SPE URANUS requires its employees to comply with this Policy by informing them of the key principles, requirements, and penalties for violations. 

7.10.2. The Company organizes safe, confidential and accessible means of informing management about the facts of corruption offenses. Management may receive suggestions for improving anti-corruption measures and controls, as well as requests from employees and third parties to the following email address: info@spe-uranus.com.

7.10.3. In order to create an appropriate level of anti-corruption culture, new employees are given introductory training on the provisions of this Policy and related documents. 

7.11. Interaction with contractors. The company declares openness in the fight against corruption. Seeks to minimize the risk of business relationships with counterparties that may be involved in corrupt activities. The company seeks to have business relations with contractors who support the requirements of anti-corruption legislation and (or) declare their rejection of corruption. 

7.12. Refusal of retaliatory measures and sanctions. SPE URANUS declares that no employee will be sanctioned (including dismissed, demoted, or stripped of bonuses) if they report alleged corruption, or if they refuse to pay or receive a bribe, commit commercial bribery, or mediate bribery, including if the Company has lost profits or has not obtained commercial and competitive advantages as a result of such refusal. 

7.13. Internal financial control 

7.13.1. The main purpose of internal financial control is to confirm the reliability of the Company's accounting and reporting, and to comply with the current legislation of the Russian Federation regulating the procedure for conducting financial and economic activities. 

7.13.2. The Company's internal control system provides: 

- accuracy and completeness of accounting documentation, prevention of errors and distortions; 

- timely preparation of reliable financial statements; 

- execution of orders and orders of the Company's Director; 

- implementation of the Company's financial and economic activity plans; 

- preservation of the Company's property. 

7.13.3. Control system condition of accounting in Society includes testing: 

- compliance with the requirements of the legislation of the Russian Federation regulating the procedure for conducting financial and economic activities;

- accuracy and completeness of accounting documents and registers; 

- prevention of possible errors and distortions in accounting and reporting; 

- execution of orders and orders of the management; 

- control over the safety of the Company's financial and non-financial assets. 

7.13.4. Control of documentation of operations of economic activity of SPE URANUS is primarily associated with the obligation to maintain financial (accounting) statements by the Company and is aimed at preventing and detecting relevant violations: preparation of unofficial reports, use of forged documents, recording of non-existent expenses, absence of primary accounting documents, corrections in documents and reports, destruction of documents and reports before the established deadline, etc. 

7.13.5. Verification of the economic validity of transactions in the areas of corruption risk can be carried out in relation to the exchange of business gifts, representation expenses, charitable donations, remuneration to external consultants and other areas. At the same time, you should pay attention to the presence of circumstances – indicators of illegal actions. 

7.13.6. All financial transactions must be accurately, correctly and with a sufficient level of detail reflected in the accounting records of SPE URANUS , documented and available for verification. 

7.13.7. Misrepresentation or falsification of the company's accounting statements is strictly prohibited and is regarded as fraud. 

7.14. Informing. 

7.14.1. SPE URANUS places this Policy in free access on the official website on the Internet, openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Regulation by all contractors, their employees and other persons. 

7.14.2. SPE URANUS contributes to raising the level of anti-corruption culture by informing and educating employees in order to maintain their awareness of the company's anti-corruption policy. 

7.15. Prevention of corruption 

7.15.1. the Company informs employees about the anti-corruption legislation of the Russian Federation, measures taken by the Company for this purpose, as well as the provisions and requirements of this anti-Corruption policy. 

7.15.2. the Company conducts introductory training for all newly hired employees of the Company regarding the applicable requirements of anti-corruption legislation and internal documents of the Company 

7.15.3. the Company requires its employees to comply with the company's anti-Corruption policy, informing them of the key principles, requirements and sanctions for violations. All employees of the Company must be guided by the company's anti-Corruption policy and strictly comply with its principles and requirements. 

7.15.4. Any employee who doubts the legality of their actions, as well as actions, omissions or proposals of other employees, contractors or other persons interacting with the company, in accordance with the principles and requirements of the anti-corruption policy, must inform their direct Manager and/or authorized person, who, if necessary, will provide recommendations and explanations regarding the situation. 

7.16. Anti-corruption measures. SPE URANUS plans to implement the following anti-corruption measures in order to prevent and counter corruption: 

7.16.1. Training and informing employees: 

- familiarization of employees with the regulatory documents regulating the prevention and counteraction of corruption in the enterprise; 

— conducting training events on the prevention and counteraction of corruption; 

- organization of individual consulting of employees on the application (compliance) of anti-corruption standards and procedures; 

7.16.2. Ensuring that the company's internal control system meets the requirements of the anti-corruption policy: — control of accounting data, availability and reliability of primary accounting documents. 

RESPONSIBILITY 

8.1. the company's Management and employees, regardless of their position, are responsible for compliance with the principles and requirements of the company's anti-Corruption policy, as well as for actions (inaction) of their subordinates that violate these principles and requirements. 

8.2. The sanctions for corruption in the Society include: measures of criminal, administrative and disciplinary liability in accordance with the legislation of the Russian Federation and measures of corporate impacts in compliance with the legal acts of the company. 

8.3. the Company has the right to conduct internal audits for each reasonable suspicion or established fact of corruption within the limits permitted by the legislation of the Russian Federation. 

COOPERATION WITH LAW ENFORCEMENT AGENCIES IN THE FIELD OF ANTI-CORRUPTION 

9.1. Cooperation with law enforcement agencies is an important indicator of the actual commitment of SPE URANUS to the declared anti-corruption standards of conduct. This cooperation can take various forms: 

— it is necessary to inform the relevant law enforcement agencies about cases of corruption offenses that have become known in the Society; 

— providing assistance to authorized representatives of control, Supervisory and law enforcement agencies in conducting inspections of the company's activities on issues of preventing and combating corruption; 

— assistance to authorized representatives of law enforcement agencies in carrying out measures to prevent or investigate corruption crimes, including operational search activities; 

— the company's management and employees should not allow interference in the performance of official duties by judicial or law enforcement officials. 

MODIFICATION 

10.1. In identifying the lack of effective measures hereof or related anti-corruption measures SPE URANUS, or change the requirements of applicable legislation of the Russian Federation, the management of SPE URANUS, as well as a responsible person, organize the development and implementation of the action plan for the revision and amendment of this Provision and(or) anti-corruption measures.