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It is registered

Ministry of Justice of Ukraine

December 31, 2021

No. 1702/37324

THE ORDER OF THE NATIONAL AGENCY CONCERNING PREVENTION OF CORRUPTION OF UKRAINE

of December 10, 2021 No. 794/21

About approval of the Standard anti-corruption program of the legal entity

According to Item 12 parts one of Article 11, Item 5 parts one of Article 12, article 63 of the Law of Ukraine "About prevention of corruption" PRIKAZYVAYU:

1. Approve the Standard anti-corruption program of the legal entity which is attached.

2. Declare invalid the decision of the National agency concerning prevention of corruption of March 2, 2017 No. 75 "About approval of the Standard anti-corruption program of the legal entity", registered in the Ministry of Justice of Ukraine on March 09, 2017 for No. 326/30194.

3. Determine that the legal entities specified in part two of article 62 of the Law of Ukraine "About prevention of corruption" approve the anti-corruption programs on the basis of the Standard anti-corruption program of the legal entity approved by Item 1 of this order.

4. To provide to department of prevention and identification of corruption in accordance with the established procedure this order on state registration to the Ministry of Justice of Ukraine.

5. I reserve control of execution of this order.

6. This order becomes effective from the date of its official publication.

Chairman

A. Novikov

Approved by the Order of the National agency concerning prevention of corruption of Ukraine of December 10, 2021 No. 794/21

Standard anti-corruption program of the legal entity

Preamble (values)

This Anti-corruption program (further - the Program)-1 __________________ (full name of the legal entity) (further - the Company), realizing responsibility for approval of values of supremacy of law and virtue, aiming to provide the sustainable development, caring for own goodwill, for encouragement of use of fair commercial practice, and also in interests, in particular, but not only, the founders, workers, business partners, clients proclaims that her founders (participants) - 2, governing bodies, officials and workers in the activities, and also in legal relationship with business partners, public authorities, local government bodies, other legal entities and physical persons are guided by the principle of zero tolerance to corruption in any its forms and manifestations and use measures concerning prevention, identification and anti-corruption (apply) all, stipulated by the legislation, and this Program.

The company declares the principled stand and condemns corruption as illegal and unethical method of conducting activities.

I. General provisions

1. Determination of terms

1. In this Program the provided terms are used in such values:

charity - the voluntary personal and/or property help which is directed to assistance to legitimate interests of receivers of the charitable help in the spheres of charity determined by the law which assumes receipt of profit by the Company, and also payments of any remuneration or compensation of the Company from name or at the request of the receiver of the charitable help;

fee in support of political party - money or other property, benefits, privileges, services, loans (credits), intangible assets, any other benefits of intangible or non-cash nature, sponsorship of actions or other activities in support of batch, the goods, works, the services provided by the Company gratuitously or on favorable terms (at the price below market value of identical or similar works, goods and services in the corresponding market) received by political party, its local organization which in accordance with the established procedure acquired the status of the legal entity;

business hospitality - representative actions (for example, business breakfasts, lunches, dinners, buffet receptions, tastings, other actions (conferences, cultural and sporting events)), expense recovery for the road, accommodation, other expense types which are performed by the Company or the Companies for the purpose of establishment or adjustment of business relations or with other purpose connected with activities of the Company;

business relations - the relations between the Company and the business partner connected with business, professional or economic activity of the Company, which arose based on the agreement or implementation of other activities by the Company also provide existence duration after their establishment;

business partners - legal entities and/or physical persons with which the Company supports, enters or intends to enter business relations;

the encouraging payments - unofficial and illegal payments to officials for the purpose of assistance/acceleration/simplification or, in certain cases, proper accomplishment of the procedures established by the legislation which the Company has legitimate right to receive, without making such payments;

corruption risk - probability of making of the corruption or connected with corruption offense, other violation of the law of Ukraine "About prevention of corruption" which will negatively influence activities of the Company;

illegal benefit - money or other property, benefits, privileges, services, intangible assets, any other benefits of intangible or non-cash nature which offer, promise, provide or receive without the bases, legal on that;

zero tolerance to corruption - absolute intolerance to corruption in any its manifestations;

the representative of the Company - person authorized in accordance with the established procedure to act on behalf or for the benefit of the Company in relations with the third parties;

official:

person authorized on accomplishment of functions of the state or local self-government according to Item of 1 part one of article 3 of the Law of Ukraine "About prevention of corruption";

person who is equated to persons authorized on accomplishment of functions of the state or local self-government according to Item 2 parts one of article 3 of the Law of Ukraine "About prevention of corruption";

the employee of foster service according to article 92 of the Law of Ukraine "About public service";

the presidential candidate of Ukraine and the candidate for People's Deputies of Ukraine registered according to the procedure, established by the law;

the head, other official of economic society in which the state or municipal share exceeds 50 percent;

the foreign official (person holding position in legislative, executive or judicial authority of the foreign state, including jury members, other persons performing functions of the state for foreign state, including for state body or the state company);

the foreign arbitration judge, person, authorized to solve civil, commercial or employment disputes in foreign state according to the procedure, alternative judicial;

the official of the international organization (the employee of the international organization, or any other person authorized by such organization to be effective from her name);

the member of the international parliamentary assembly which participant is Ukraine;

judge and official of international court;

sponsor's activities (sponsorship) - voluntary material, financial, organizational and other support by the Company of any action or activities for the purpose of promoting of the name of the Company, signs for goods and company services.

2. Other terms in this Appendix are used in the values given in the Law of Ukraine "About prevention of corruption".

2. Purpose and scope of application

1. The purpose of this Program is ensuring functioning of effective system of prevention and anti-corruption, compliance of activities of the Company to requirements of the anti-corruption legislation taking into account the best world practices.

2. This Program establishes package of measures (rules, standards and procedures) concerning prevention, identification and anti-corruption in activities of the Company, not smaller on amount and content, than is provided by the Law of Ukraine "About prevention of corruption" and the Standard anti-corruption program of the legal entity approved by the order of the National agency concerning prevention of corruption.

3. Measures for prevention, identification and elimination or minimization of corruption risks are recognized priority activities of the Company.

4. This Program is obligatory for execution by founders (participants), the head, governing bodies, officials of all levels, workers, representatives of the Company and persons who are trained in the Company or perform certain work based on the civil agreements signed with the Company.

5. This Program is obligatory for all subjects of managing (affiliated enterprises, separate divisions, branches, representations) over which the Company exercises control.

6. This Program is applied in all fields of activity of the Company, including in the relations with business partners, officials, public authorities and local government bodies, other legal entities and physical persons.

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