ANTI-CORRUPTION
POLICY

I. GENERAL PROVISIONS
 

1. Basic Principles
 

1.1. This Anti-Corruption Policy (hereinafter referred to as the ‘Policy’) is a key internal document of Yartura Limited Liability Company (hereinafter – the Company), which sets out the fundamental principles and requirements aimed at preventing corruption and ensuring compliance with anti-corruption legislation by the Company, members of its governing bodies, employees and other persons who may act on behalf of the Company.
1.2. The Policy has been developed in accordance with the Constitution of Ukraine, the current legislation of Ukraine, the Articles of Association, the standards of corporate ethics for the Company’s employees and the Company’s internal regulations, as well as generally accepted principles of international law.
1.3. The Company recognises its responsibility for upholding the values of the rule of law and integrity, declares its principled stance, and condemns corruption as an unlawful and unethical way of conducting business in any form or manifestation.
1.4. The Company adheres to a zero-tolerance policy towards corruption, which means a complete prohibition of corrupt practices in any form.
1.5. The Company encourages compliance with the principles and requirements of this Policy by its counterparties, as well as by other persons with whom it enters into contractual relationships.
1.6. This Policy reflects the Company’s and its management’s commitment to high ethical standards of conducting open and honest business, aimed at maintaining the Company’s business reputation at an appropriate level.
 

2. Definitions
 

Close relatives — persons who live together and share a common household, including persons who live together but are not married, as well as a husband, wife, father, mother, stepfather, stepmother, son, daughter, stepson, stepdaughter, full and second cousins, sisters and cousins, the wife’s (husband’s) brother and sister, nephew, niece, uncle, aunt, grandfather, grandmother, great-grandfather, great-grandmother, grandson, granddaughter, great-grandson, great-granddaughter, son-in-law, daughter-in-law, father-in-law, mother-in-law, mother-in-law, father and mother of the wife (husband) of the son (daughter), adoptive parent or adoptee, guardian or carer, a person under the guardianship or care of the aforementioned person.
A corruption offence is an act exhibiting signs of corruption committed by a person who permanently or temporarily holds a position involving the performance of organisational, managerial, administrative or economic duties, for which criminal, administrative, disciplinary and/or civil liability is established by law.
Corruption is the act of a person who permanently or temporarily holds a position involving organisational, managerial or administrative economic duties, of the official powers vested in them or of opportunities associated therewith, for the purpose of obtaining an unlawful advantage or accepting such an advantage or accepting a promise/offer of such an advantage for themselves or other persons, or, correspondingly, the promise/offer or provision of an unlawful advantage to a person who permanently or temporarily holds a position related to the performance of organisational, managerial or administrative and economic duties, or, at their request, to other natural or legal persons, with the aim of inducing that person to misuse the official powers granted to them or the opportunities associated therewith.
Corruption risk — the likelihood of a corruption-related or corruption-linked offence being committed by the persons referred to in clause 3.2.1. of this Policy whilst performing their functional duties.
Undue advantage — funds or other property, benefits, privileges, services, intangible assets, or any other benefits of an intangible or non-monetary nature that are promised, offered, provided or received without lawful grounds.
A potential conflict of interest is a situation where a person has a private interest in an area in which they exercise their official or representative powers, which may affect the objectivity or impartiality of their decision-making, or influence whether they take or refrain from taking action whilst exercising those powers.
Gift — cash or other property, benefits, privileges, services or intangible assets provided or received free of charge or at a price below the minimum market value.
An associated company is a company, including subsidiaries, affiliated companies, branches, and divisions of legal entities, which exist or are established in the future.
Private interest – any pecuniary or non-pecuniary interest of a person, including that arising from personal, family, friendly or other non-work-related relationships with natural or legal persons, including those arising in connection with membership of or activities in public, political, religious or other organisations.
Actual conflict of interest – a conflict between a person’s private interest and their official or representative powers, which affects the objectivity or impartiality of decision-making, or the performance or non-performance of actions whilst exercising those powers.

3. Purpose and Scope

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3.1. The purpose of this Policy is to ensure the operation of an effective system for preventing and combating corruption within the Company by achieving the following objectives:
3.1.1. implementing a set of measures aimed at improving the Company’s corporate culture, applying best practices in corporate governance and standards of responsible business conduct;
3.1.2. minimising the risks of the Company, its management and employees becoming involved in corrupt activities;
3.1.3. fostering a shared understanding among employees, contractors and other persons interacting with the Company that corruption in any form or manifestation is absolutely unacceptable;
3.1.4. ensuring that the Company’s activities comply with the requirements of Ukraine’s anti-corruption legislation, taking into account international best practices.
3.2. Scope of the Policy:
3.2.1. This Policy applies to:
•    the founders (members) of the Company;
•    the management and members of the Company’s governing bodies;
•    the Company’s employees, regardless of their position or duties;
•    counterparties, affiliates of the Company and other persons acting on behalf of the Company on the basis of a power of attorney or other grounds.
3.2.2. The provisions of this Policy apply to all areas of the Company’s activities, in particular to relations with counterparties, state and local government bodies, and other persons.
3.2.3. The Company’s Head is responsible for organising the implementation of the principles and requirements of this Policy, including the appointment of responsible persons.
3.3. The text of this Policy is permanently available in an open format to all Company employees and other interested parties.

4. Principles of the Anti-Corruption Policy

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4.1. Leadership and management accountability. The Company’s management demonstrates zero tolerance towards any form or manifestation of corruption at all levels, setting an example through their conduct and ensuring that all employees and contractors of the Company are made aware of this Policy.
4.2. Effectiveness of anti-corruption measures. The Company implements necessary and sufficient measures to prevent, detect and combat corruption in its activities, and continuously monitors and improves them.
4.3. Comprehensive vetting of business partners. The Company applies a risk-based approach to the selection of counterparties, assessing their anti-corruption and sanctions policies, their willingness to adhere to ethical standards of business conduct and to include relevant terms (clauses) in contracts, as well as to provide mutual support for ethical business conduct and the prevention of corruption.
4.4. Development of an anti-corruption culture. The Company ensures the transparency of the Policy by publishing it publicly, conducts regular training for employees, and encourages the implementation of anti-corruption practices among counterparties. Fostering a strong anti-corruption culture is a priority for the Company.
4.5. Continuous improvement. The Company regularly monitors the effectiveness of anti-corruption procedures and their relevance to current challenges, ensuring the timely updating and adaptation of the anti-corruption system.
 

II. RIGHTS, OBLIGATIONS AND PROHIBITIONS
 

1. Rights and obligations of the founders (shareholders), the director, members of the management bodies, employees and representatives of the Company
 

1.1. All employees of the Company, regardless of their position and duties, have the right to:
1.1.1. make proposals for improving anti-corruption measures and the provisions of the Policy;
1.1.2. to consult their immediate supervisor or the Company’s management regarding the implementation of anti-corruption procedures and for clarification of the provisions of anti-corruption legislation;
1.1.3. receive recommendations from the Company’s management regarding the assessment of corruption risks in their activities and ways to minimise them;
1.1.4. report any signs of breaches of this Policy and propose measures to address them.
1.2. The founders (shareholders), management and employees of the Company, regardless of their position, are obliged to:
1.2.1. strictly comply with the provisions of this Policy and other internal regulations of the Company in the field of corruption prevention;
1.2.2. to perform their duties conscientiously, honestly and impartially, taking into account the legitimate interests of the Company;
1.2.3. immediately notify their immediate supervisor or the Company’s management of: 

instances of breach of the requirements of this Policy; 

instances of incitement to commit acts of corruption; 

corrupt or corruption-related offences committed by Company employees or contractors;

1.2.4. to promptly report the occurrence of any actual or potential conflict of interest and take measures to resolve it;
1.2.5. to refrain from any conduct that may be construed as a willingness to commit a corruption offence;
1.2.6. comply with the Company’s established rules regarding business hospitality, and the giving and receiving of gifts;
1.2.7. refrain from clearly unlawful actions, decisions and instructions, and take measures to revoke such instructions;
1.2.8. participate in anti-corruption measures organised by the Company.
1.3. The Head of the Company or a person authorised by them is also obliged to:
1.3.1. set an example of ethical conduct to foster a zero-tolerance attitude towards corruption among employees;
1.3.2. ensure regular assessment of corruption risks in the Company’s activities;
1.3.3. ensure the implementation of and monitor compliance with anti-corruption measures;
1.3.4. respond promptly to reports of breaches of the anti-corruption policy;
1.3.5. respond promptly to reports of actual or suspected corruption offences committed by members of the Company’s management bodies or employees.
1.3.6. ensure the confidentiality of information regarding individuals who report corruption offences;
1.3.7. provide employees with guidance on the application of anti-corruption procedures;
1.3.8. encourage all employees to demonstrate leadership in preventing and combating corruption within the scope of their responsibilities.
1.4. Employees may be subject to disciplinary action for breaches of this Policy in accordance with the applicable legislation of Ukraine and the Company’s internal regulations.
1.5. The Company reserves the right to report any alleged corruption offences to the law enforcement authorities.

 

2. Prohibited corrupt practices

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2.1. The management, members of the governing bodies, employees and representatives of the Company are prohibited from:
2.1.1. accepting an offer or promise, or receiving an undue advantage, or soliciting such an advantage for themselves or for another natural or legal person in return for performing or refraining from performing any actions by exploiting their position within the Company, or in connection with their activities on behalf of the Company, in the interests of the person offering, promising or providing such a benefit, or in the interests of a third party;
2.1.2. abuse their official powers, with the aim of obtaining an unlawful benefit for themselves or another natural or legal person, by using their powers contrary to the interests of the Company;
2.1.3. offer, promise or provide (directly or through intermediaries) an unlawful benefit to public officials, their close associates or other individuals for performing or refraining from performing actions using their official position for the benefit of the Company;
2.1.4. make decisions or take action in circumstances where there is an actual conflict of interest;
2.1.5. use the Company’s property or funds for personal purposes;
2.1.6. organise, act as an intermediary in, or personally make any cash or non-cash payments or settlements with the Company’s counterparties, other natural or legal persons, if such payments or settlements are not provided for by law or by legal transactions entered into by the Company;
2.1.7. influence the decisions of the Company’s employees with the aim of obtaining an unlawful benefit for oneself or others;
2.1.8. take any action that directly or indirectly incites other employees to breach the requirements of this Policy;
2.1.9. give or receive gifts in breach of the law and the Company’s rules on business hospitality;
2.1.10. after the termination of their relationship with the Company, disclose or use confidential information for personal gain (except where permitted by law).
2.2. The Company prohibits any incentive payments to public officials, in particular for the purpose of expediting formal procedures or obtaining advantages.
2.3. Amounts paid officially into the account of a public authority, local government body or the budget in accordance with the law shall not be considered incentive payments.
2.4. An employee or representative of the Company who is asked to make an inducement payment must inform the person making such a request that such payments are prohibited, refuse to make such a payment, and immediately inform their immediate supervisor of the request received.
2.5. Should an employee or representative of the Company have any doubt as to whether a payment constitutes an inducement and is prohibited, such employee or representative of the Company must seek advice from their immediate supervisor.
2.6. All the above prohibitions apply without any territorial restrictions, in any country, regardless of national traditions, local practices or competitive conditions prevailing in that country.

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III. PREVENTION AND MONITORING MEASURES

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1. Prevention and resolution of conflicts of interest. Typical situations.

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1.1. The Company takes measures to ensure that conflicts of interest do not adversely affect the interests of the Company, as well as the interests of its clients/customers, founder(s)/participant(s), by preventing, identifying and resolving conflicts of interest.
1.2. The prevention and resolution of conflicts of interest is based on the following principles:
1.2.1. the obligation to report situations that appear to involve a conflict of interest;
1.2.2. preventing conflicts of interest from arising;
1.2.3. an individual approach to each case.
1.3. Employees are required, no later than the next working day following the date on which they became aware or should have become aware of an actual or potential conflict of interest, to notify their immediate supervisor in writing, to refrain from taking any action or making any decisions whilst an actual conflict of interest exists, and to take steps to resolve the actual or potential conflict of interest.
1.4. In the event of an actual or potential conflict of interest arising in relation to a director of the Company, the director is obliged to notify in writing the person or body responsible for dismissing or initiating the dismissal of the director from office.
1.5. The employee’s immediate supervisor shall, within two working days of receiving notification of a conflict of interest, decide on the method of resolving it and inform the employee of the decision taken.
1.6. The immediate supervisor who becomes aware of a conflict of interest involving an employee under their supervision (including where they independently identify a conflict of interest in a subordinate without the subordinate having made the relevant notification) is obliged to take the measures provided for in this Policy to prevent and resolve the conflict of interest.
1.7. Conflicts of interest may be managed through one or more of the following measures:
1.7.1. removing the employee from carrying out a specific task, making a decision or participating in the decision-making process where a conflict of interest exists;
1.7.2. establishing external oversight of the performance of the relevant task, the carrying out of specific actions or the making of decisions;
1.7.3. restricting the employee’s access to certain information;
1.7.4. reviewing and amending the scope of the employee’s duties;
1.7.5. transferring the employee to another post (with their consent and subject to the availability of a suitable vacancy).
1.8. The procedure for applying measures to resolve conflicts of interest for different categories of persons shall be determined by the manager or a person authorised by them, taking into account the following conditions:
1.8.1. the transfer of an employee to another post shall be applied only with their consent if the actual or potential conflict of interest in the employee’s activities is of a permanent nature and cannot be resolved by other means, and provided there is a vacant post whose characteristics correspond to the employee’s personal and professional qualities;
1.9. In the event of an actual or potential conflict of interest involving a representative of the Company, the legal relationship with that person shall be terminated. If the conflict is of a permanent nature, that person shall be included in the list of persons whose services are not used by the Company and/or to whom no payments are made. 
1.10. A decision to resolve a conflict of interest in the activities of the Company’s director shall be taken by the person or body (including a collegial body) whose powers include the dismissal or initiation of dismissal from the post of the Company’s director, within two working days of receiving notification. The person concerned shall be notified of the decision without delay. 
1.11. An employee may independently resolve a conflict of interest by relinquishing the relevant private interest and providing supporting documents.
1.12. The Company’s manager may independently resolve a conflict of interest by relinquishing the private interest and providing supporting documents to an authorised person or body. 
1.13. In the event of an actual or potential conflict of interest arising in a person who is a member of a collegial body (a management body of the Company (supervisory board, management board, other executive body), a commission, a working group, a tender committee, etc.), when that body is deciding on a matter, such person shall notify the relevant collegial body of this in writing.
1.14. In such cases, the person in question is prohibited from:
1.14.1. taking part in the preparation of documents for the decision-making process on the matter in question; 
1.14.2. taking part in the consideration (discussion) of the matter in question;
1.14.3. voting on the matter in question.
1.15. If the non-participation of a member of a collegial body would result in the body losing its authority, their participation in the decision-making process is permitted only under external supervision. The decision on external supervision is taken by the collegial body.
1.16. Typical situations involving a conflict of interest may include:
1.16.1. participating in or making a decision regarding the conclusion of an employment contract, promotion, determination of remuneration terms and the application of financial incentives, or the imposition of penalties in relation to a close relative;
1.16.2. entering into transactions on behalf of the Company with close associates;
1.16. 3. participating in or making a decision that may influence the receipt of benefits by another business entity over whose business decisions such a person or their close relative exercises actual control, in which such a person or their close relative is a founder (shareholder), employee, receives or has received remuneration or gifts, or has undergone or is undergoing training;
1.16.4. performing the functions of a senior manager in another legal entity whose interests may conflict with those of the Company;
1.16.5. making decisions concerning oneself personally (remuneration, granting of benefits, internal investigations, etc.);
1.16.6. participating in or making decisions regarding counterparties with whom the employee or their close associates have personal, financial or business ties;
1.16.7. receiving valuable gifts from counterparties if this is related to decision-making;
1.16.8. the employee or their close associates holding a share in the authorised capital of competing companies or companies that have business relations with the Company;
1.16.9. the employee engaging in public political, social or charitable activities, if the Company’s name, information, time, property or other resources are used in doing so;
1.16.10. engaging in or being involved in activities that create any competition with the Company and/or its Affiliated Companies, both during the term of the employment/contractual relationship and for a specified period following its termination;
1.16.11. participating in any projects that directly or indirectly compete with the activities of the Company and/or its Affiliates without obtaining prior written consent.

2. Interaction with counterparties

2.1. The Company endeavours to work only with counterparties that conduct their business lawfully and ethically, and with whom interaction does not pose any corruption risks to the Company.
2.2. Prior to commencing cooperation, the Company informs potential counterparties of its anti-corruption principles and requirements, as well as the verification procedure.
2.3. The Company carries out checks on potential counterparties (prior to the conclusion of legal transactions) and existing counterparties (after establishing legal relations with them).
2.4. The vetting is carried out by the relevant departments of the Company.
2.5. The procedure and frequency of vetting the Company’s counterparties are set out in the Company’s internal regulations.
2.6. The vetting of the Company’s counterparties is carried out with the aim of:
2.6. The Company conducts checks on its counterparties for the following purposes
2.6.1. assessing the counterparty’s business reputation with regard to tolerance of corruption, namely: whether the counterparty has a reputation as an entity whose activities are linked to corruption (even in the absence of relevant court rulings), and whether the counterparty will act as an intermediary for the transfer to third parties (or for the receipt from third parties) of unlawful benefits;
2.6.2. verifying whether the counterparty has anti-corruption policies in place, the status of their actual implementation, and their willingness (or refusal) to comply with the Company’s principles and requirements, as well as anti-corruption legislation;
2.6.3. identifying potential corruption risks in connection with the conclusion (performance) of a transaction;
2.6.4. minimising the likelihood of committing, or verifying possible instances of, corruption or corruption-related offences, or other breaches of anti-corruption legislation, during the establishment and/or implementation of legal relations with the counterparty.
2.6.5. In the event of reasonable doubts regarding the business reputation of a counterparty, which may lead to corruption risks for the Company, the Company reserves the right to refuse to establish or continue cooperation with the counterparty.
2.6.6. Anti-corruption clauses shall be included in the agreements (contracts) that the Company enters into with counterparties. The purpose of the anti-corruption clause is for the Company to provide guarantees of compliance with the anti-corruption legislation applicable to it and to obtain similar guarantees from the counterparty.
 

3. Business hospitality policy and procedures. Gifts
 

3.1. The Company shall establish general policies and procedures for offering and accepting business hospitality and gifts, in accordance with the requirements of the law.
3.2. The Director, members of the governing bodies, employees and representatives of the Company are obliged to refrain from offering business hospitality or gifts to public officials, their close associates, actual or potential counterparties, their employees or representatives, if such business hospitality or gifts may be construed as an inducement or willingness to commit a corruption offence related to the Company’s activities.
3.3. The giving and receiving of gifts, as well as the offering and acceptance of business hospitality, within the scope of establishing or maintaining business relations or for the achievement of other objectives of the Company’s activities, is permitted provided that it meets all of the following criteria:
3.3.1. is not intended to influence the objectivity of any decision regarding the conclusion of legal transactions, the provision or receipt of services, information, or any other benefits for the Company;
3.3.2. does not constitute a concealed improper benefit;
3.3.3. complies with generally accepted standards of hospitality;
3.3.4. is not prohibited by the laws of the country in which it is provided and/or accepted;
3.3.5. does not exceed the limits set by law;
3.3.6. is not prohibited under the recipient organisation’s internal documents and does not exceed the value specified in such documents;
3.3.7. disclosure of the gift or business hospitality will not pose a risk to the business reputation of the Company or of the person who received the gift or business hospitality;
3.3.8. gifts and business hospitality are reasonable, not excessive and appropriate in the context of establishing or maintaining business relations.
3.4. The giving and receiving of gifts in the form of funds (cash or non-cash) or the equivalent of funds (gift cards or gift vouchers) is not permitted.
3.5. If there is any doubt as to the acceptability of a gift or business hospitality, employees must consult their line manager in accordance with the procedure set out in this Policy to seek advice and/or clarification.

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4. Charitable and sponsorship activities

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4.1. The Company may engage in charitable and sponsorship activities provided that there are no prohibitions imposed by legislation or the Company’s internal regulations.
4.2. Charitable and sponsorship activities shall be carried out in accordance with the requirements of the law and provided that there are no corruption risks.
4.3. A person authorised by the Company’s director shall carry out a preliminary review of planned charitable and sponsorship activities and approve draft legal transactions relating to the conduct of such activities in order to ensure that charitable and sponsorship assistance is not used as an improper benefit or for any other unlawful purpose.
4.4. The Company shall not engage in charitable or sponsorship activities if:
4.4.1. such activities are a condition for the conclusion of any transaction, the adoption of a decision by a state or local government body, or are aimed at obtaining unlawful advantages in business activities;
4.4.2. the counterparty insists that such activities be carried out exclusively through a specific organisation;
4.4.3. it is carried out with the aim of influencing a public official or in exchange for any unlawful benefit for the Company from the counterparty. 
4.5. The main tools for monitoring charitable and sponsorship activities are:
4.5.1. vetting potential recipients of aid in accordance with the procedure applied to the vetting of the Company’s counterparties;
4.5.2. monitoring the intended use of aid, as determined by the Company itself.

5. Screening of candidates for positions
 

5.1. The Company screens candidates for positions that are vulnerable to corruption risks as part of its recruitment procedures.
5.2. The vetting of candidates for positions is carried out with the aim of:
5.2.1. determining whether entering into an employment contract with the candidate would create corruption risks for the Company or a potential conflict of interest;
5.2.2. ensuring that the conclusion of an employment contract will not result in a breach of anti-corruption legislation;
5.2.3. obtaining a commitment from the candidate to comply with the requirements of this Policy;
5.3. The decision to conclude an employment contract is made in accordance with the requirements of anti-corruption legislation.

6. Anti-corruption clause in contracts

6.1. An anti-corruption clause must be included in all contracts entered into by the Company with its counterparties.
6.2. The anti-corruption clause provides for: 
6.2.1. mutual obligations of the parties to comply with anti-corruption legislation and the Company’s Anti-Corruption Policy.
6.2.2. provisions regarding the absence of conflicts of interest between the parties’ representatives.
6.2.3. a prohibition on offering, promising or providing remuneration, a gift or any other advantage, privilege or benefit in exchange for simplifying formalities in connection with the performance of the contract.
6.2.4. the right to unilaterally terminate the contract in the event of a breach of anti-corruption obligations.
6.3. A counterparty’s refusal to include an anti-corruption clause in the contract is regarded as a risk factor and may constitute grounds for refusing to enter into contractual relations.
6.4. In the event of a breach of the anti-corruption clauses by the counterparty, the Company shall take measures to hold the counterparty liable in accordance with the contract.
 

IV. REPORTS, THEIR INVESTIGATION AND LIABILITY
 

1. Reports of possible instances of corruption or corruption-related offences

1.1. The Company creates a supportive environment for individuals who report potential breaches of this Policy or indications of corruption or corruption-related offences (hereinafter referred to as ‘whistleblowers’), and fosters a culture of respect for whistleblowers as an integral part of its corporate values.
1.2. The Company provides whistleblowers with the means to report possible instances of corruption or corruption-related offences (hereinafter referred to as ‘reports’) by:
1.2.1. mandatorily establishing and ensuring the operation of channels through which a person may make a report whilst guaranteeing their anonymity (hereinafter referred to as ‘reporting channels’);
1.2.2. receiving and reviewing reports, investigating them and responding to them;
1.2.3. providing guidance and advice on making reports to potential whistleblowers;
1.2.4. implementing incentive mechanisms and fostering a culture of reporting;
1.2.5. upholding the rights and safeguards of whistleblowers.
1.3. Information regarding reporting channels shall be brought to the attention of all employees (including upon recruitment) and shall be made permanently available to all employees of the Company and other interested parties.
1.4. Reports must contain verifiable factual information confirming the possible commission of a corruption-related offence or an offence linked to corruption.
1.5. The development of a culture of reporting is supported through the Company’s internal policies on ethical conduct and respect for whistleblowers.

2. Procedure for responding to reports of possible corruption or corruption-related offences

2.1. Upon receipt of a report or the independent detection of signs of a corruption-related offence, the person authorised by the head of the organisation shall conduct a preliminary review of the information received.
2.2. Based on the results of the preliminary review, one or more decisions shall be taken:
2.2.1. to take measures to remedy the identified breach;
2.2.2. to initiate an internal investigation (if the facts are confirmed or require further clarification);
2.2.3. to close the proceedings (if the facts are not confirmed). 
2.3. An internal investigation is conducted to verify the facts set out in the report regarding a possible breach of this Policy or anti-corruption legislation. 
2.4. The internal investigation is conducted by a commission comprising the person authorised by the Company’s management who carried out the preliminary review.
2.5. All employees of the Company are required to cooperate with the internal investigation and to provide the necessary documents and materials in their possession.
2.6. An employee of the Company who is the subject of an internal investigation may be temporarily suspended from work or otherwise restricted in their access to the Company’s material, information and other resources for the duration of the internal investigation, based on a decision by the Company’s management.
2.7. Based on the results of the internal investigation, the following decision(s) shall be taken:
2.7.1. to take measures to remedy the identified breach;
2.7.2. to impose disciplinary sanctions on the persons responsible;
2.7.3. to determine ways of eliminating the causes and conditions of the violation, the consequences resulting therefrom, and to implement measures to prevent such violations in the future;
2.7.4. to implement measures to restore the rights and legitimate interests of individuals and to compensate for losses and damage caused to natural and legal persons as a result of the violations committed;
2.7.5. forward the materials to the pre-trial investigation authority if signs of a criminal offence are established, or to other authorities authorised to respond to the identified offences.
2.8. The duration of the internal investigation shall not exceed 30 (thirty) calendar days from the date of completion of the preliminary review. If it is not possible to verify the reported (identified) information within the specified period, the head of the Company shall extend the duration of the internal investigation to 45 days.
2.9. The procedure for conducting internal investigations shall be determined by the Company.

3. Liability for breaches of this Policy

3.1. In the event of a breach of the provisions of this Policy, disciplinary measures shall be applied to the Company’s employees in accordance with the applicable legislation of Ukraine, the Company’s internal labour regulations, and the provisions of employment contracts.
3.2. Persons found guilty of breaching the requirements of this Policy and anti-corruption legislation may also be held administratively, civilly or criminally liable at the initiative of the Company, law enforcement agencies or other persons in the manner and on the grounds specified by the Company’s local regulations and the applicable legislation of Ukraine.
 

V. AMENDMENTS TO THIS POLICY
 

1. Amendments to this Policy
 

1.1. The Company’s Head shall ensure feedback mechanisms and internal processes for the continuous improvement of the Policy.
1.2. The Policy is reviewed based on the results of:
1.2.1. monitoring and control of compliance with it, and an assessment of the effectiveness of the measures implemented;
1.2.2. changes in legislation, in particular anti-corruption legislation, that affect the Company’s activities.
1.3. Amendments to the Policy may be initiated by a person authorised by the Company’s management, as well as by the founders (shareholders), the management (executive body), the supervisory board, or the Company’s employees.