Corruption control

JSC "Reimpex" has adopted a number of regulations aimed at eliminating legal and reputational risks, e.g. the Company has implemented the “JSC "Reimpex" Code of Business and Corporate Ethics”, the provisions of which are mandatory for all managers and employees, and an electronic notification system for reporting the Code violations.

The Management Board regularly assesses the corruption risks inherent to the industries and jurisdictions where the Company business is performed. The Board also reviews the disclosed occurrences of the conflict of interest, for which appropriate response actions are taken, up to and including termination of employment. Since the introduction of the above procedures, a number of employees who had committed gross violations of corporate standards have been dismissed. Some case files have been submitted to the law enforcement agencies of the Russian Federation.

JSC "Reimpex" has performed a scope of actions to apply transparent mechanisms and implement efficient procurement procedures. The Company also regularly interacts and exchanges information with government supervisory bodies, in particular, with the Russian Ministry of Finance, Federal Financial Monitoring Agency, Russian Audit Chamber, and the Central Bank of the Russian Federation.

Pursuant Article 1 of Federal Law No. 273-FZ of 25.12.2008 "On Counteracting Corruption", the following actions are recognized as corruption:

• abuse of power, giving or receiving bribes, abuse of authority, commercial bribery or other unlawful use of their official position by an individual, contrary to the legitimate interests of the society and the state, in order to obtain benefits in the form of money, valuables, other property or services of a property nature, other property rights, for themselves or for third parties, or unlawful provision of such benefits to such a person by other individuals;


• committing the acts specified in subparagraph "a" above, on behalf of or in the interests of a legal entity.JSC "Reimpex" is a public company with securities traded in Russian and foreign trading facilities, including Moscow Stock Exchange and the London Stock Exchange; therefore the Company's activities and actions of its employees in any country worldwide are to comply, inter alia, with the requirements of the Russian anti-corruption legislation, the UK Bribery Act 2010, the FCPA (Foreign Corrupt Practices Act 1977) and provisions of other laws and regulations of foreign countries where the Company operates or intends to run its business.