Anti-corruption policy of the company Rekadro

The anti-corruption policy establishes the basic anti-corruption principles of Rekadro LLC (hereinafter referred to as the Company), the managerial and organizational bases for preventing and combating corruption, minimizing and / or eliminating the consequences of corruption offenses.
1. General Provisions

1.1. The policy is developed in accordance with the laws of the Russian Federation, the Charter and other internal documents of the Company, taking into account the requirements of counterparties, customers, partners and other persons with whom the Company enters into any relationships.
1.2. The policy is aimed at combating corruption both within the Company and in the Company's relations with third parties, including state and municipal bodies, legal entities and individuals.
1.3. The policy is designed for individuals working at all levels and in all divisions of the Company, including top management, managers, employees (permanent or temporary). Its general principles and prohibitions also apply to third parties (both natural and legal) working on behalf of the Company. Neither the Company nor any of the employees of the Company has the right to circumvent the requirements of this Policy by using third parties.
1.4. The organization of all activities aimed at implementing the principles and requirements of this Policy is the responsibility of the Deputy General Director for Development.
2. Basic principles of anti-corruption

Anti-corruption in the Company is based on the following basic principles:

  • recognition, ensuring and protection of the fundamental rights and freedoms of a person and citizen;
  • legality;
  • public and open activities;
  • integrated use of managerial, organizational, informational, socio-economic, legal, special and other measures;
  • priority application of measures to prevent corruption;
  • cooperation in the field of anti-corruption activities with government agencies, as well as with partners and customers of the Company.
3. Obligations of the Company and employees of the Company.

3.1. The company and all employees must comply with the norms of the Russian anti-corruption legislation established by the Federal Law "On Combating Corruption" and other regulations, the main requirements of which are the prohibition of giving and receiving bribes, the prohibition of commercial bribery and intermediation in bribery.
3.2. Company employees are not entitled, directly or indirectly, personally or through the mediation of third parties:
a) pay for the expenses of state employees and their close relatives (or in their interests) in order to obtain the commercial advantages of the Company,
b) offer, give, promise, request and receive money, valuables, services or other benefits, make payments in favor of third parties to simplify administrative, bureaucratic and other formal procedures in any form.
c) agree or offer third parties to provide money, valuables, services, or other benefits in connection with any business transaction to influence the decision or action related to the purchase, recommendation or use of the Company's services.
3.3. Exceptions from clause 3.2. of this Policy are the Gifts and hospitality expenditures, which are directly related to the legitimate goals of the Company (external events, successful implementation of projects, generally accepted holidays). Such gifts and expenses must meet the following requirements:
- are not luxury items, comply with the requirements of the legislation of the Russian Federation;
- do not constitute hidden remuneration for a service, granting rights, making a certain decision about a transaction, agreement, license, authorization, or attempt to influence the recipient with a different illegal purpose;
3.4. Employees of the Company must notify their direct managers or the Deputy General Director for Development of all cases in which any persons have come to them in order to induce them to commit Corruption offenses.
4. Cooperation in the field of anti-corruption

The Company on the basis of the principle of reciprocity cooperates in the field of combating corruption with authorized bodies, partners, customers in order to:
a) identifying persons suspected (accused) of committing corruption crimes, their location, as well as the location of other persons involved in corruption crimes;
b) identifying property obtained as a result of corruption offenses or serving as a means of committing them;
(c) exchange of information on anti-corruption issues;
(d) Coordination of corruption prevention and anti-corruption activities.
5. Measures to prevent corruption
Prevention of corruption in the Company is carried out by applying the following basic measures:
a) Formation of intolerance to corrupt behavior among the Company's employees.
b) Anti-corruption expertise of administrative, regulatory, contractual documents, including at the stage of their preparation and coordination.
c) Presentation of qualification requirements for employees and candidates for senior positions in the Company.
d) The implementation of the rule in practice, according to which a long, flawless and effective performance by an employee of his official functions must be taken into account when promoting him/her to a higher position or encouraging.
6. Conflict of interest
6.1. Conflict of interest in this document means a situation in which the personal interest (direct or indirect) of an employee of the Company affects or may affect the proper performance of his/her functions and in which a contradiction arises or may arise between the personal interest of an employee of the Company and the rights and legitimate interests of citizens, organizations, society or the state that could cause harm to the rights and legitimate interests of citizens, organizations, society or the state.
6.2. The personal interest of an employee of the Company, which affects or may affect the proper performance of his/her functions, means the opportunity for him/her to receive income in the form of money, valuables, other property or property-related services, other property rights for oneself or third parties.
6.3. To prevent and resolve conflicts of interest, Company employees are required to:
a) take measures to prevent any possibility of a conflict of interest;
b) notify immediate superior of the conflict of interest that has arisen or of the possibility of its occurrence as soon as he/she becomes aware of this.
6.4. Preventing or resolving a conflict of interest may consist in changing the official position of an employee of the Company who is a party to a conflict of interests, up to and including his/her suspension from job in the prescribed manner, and (or) in refusing him/her from the benefit that caused the conflict of interest.
7. Responsibility for corruption offenses
Employees of the Company are subject to criminal, administrative, civil and disciplinary responsibility in accordance with the law for corruption offenses.
8. Terms and definitions
  • abuse of official position, giving a bribe, accepting a bribe, abuse of authority, commercial bribery or other unlawful use by the Company's employee of his/her official position contrary to the legitimate interests of society and the state in order to obtain benefits in the form of money, valuables, other property or or property-related services, other property rights for oneself or for third parties, or the unlawful provision of such benefits to a specified person by other individuals;
  • commission of the acts indicated above, on behalf of or in the interests of Rekadro LLC.

Anti-corruption - the activities of Rekadro LLC and officials within their powers:
  • to prevent corruption, including the identification and subsequent elimination of the causes of corruption (prevention of corruption);
  • to identify, prevent, suppress, disclose and investigate corruption offenses (fight against corruption).

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