Anti-Corruption

We adhere to the principle of zero tolerance for corruption.

The management of PANELAO FM LLC places great importance on conducting business in accordance with universally recognised anti-corruption and ethical standards, and consistently supports and endorses such fundamental company values as integrity, transparency, and accountability.

Our path is to run an open and honest business, prohibiting corruption at any time and in any form.

We undertake comprehensive efforts to prevent and combat corruption.

PANELAO FM LLC has adopted a Code of Conduct, Competition Policy, Third-Party Policy, Integrity Policy, and other documents aimed at preventing and combating corruption. These documents are drafted in accordance with legally established norms and rules, as well as leading corporate practices in this area, and compliance with their requirements is regularly reviewed.

Under any circumstances, our employees are prohibited from directly or indirectly, personally or through third-party intermediaries, offering, giving, promising, soliciting, or receiving bribes in any form to simplify administrative, bureaucratic, or other procedures.

Employees of PANELAO FM LLC must not allow situations where their personal interest or bias affects the objectivity of their professional judgement and conflicts with the interests of counterparties and partners.

We take all necessary measures to minimise the risk of business relationships with individuals and companies that have been or may be involved in corrupt activities. Our team respects fair competition and welcomes and encourages compliance with anti-corruption principles by all counterparties and partners of PANELAO.

We declare our commitment to implementing advanced tools and technologies aimed at further enhancing the transparency of our business.

The management of PANELAO FM LLC is interested in receiving timely information about ongoing or actual instances of corruption, as well as any approaches made to employees by any persons for the purpose of inducing them to commit corruption offences.

We welcome involvement and value the proactive stance of our employees, counterparties, and partners in combating corruption.

Viktor Efremov

General Director of PANELAO FM LLC

LOCAL REGULATORY DOCUMENTS

Code of Conduct

Competition Policy

Third-Party Policy

Integrity Policy

REGULATORY AND LEGAL ACTS

International Treaties

• United Nations Convention against Corruption

• Council of Europe Criminal Law Convention on Corruption

• • OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions

Federal Laws

• Federal Law No. 5-FZ of 06.02.2019 "On Amendments to Certain Legislative Acts of the Russian Federation for the Purpose of Combating Corruption"

• Federal Law No. 432-FZ of 16.12.2019 "On Amendments to Certain Legislative Acts of the Russian Federation for the Purpose of Improving the Legislation of the Russian Federation on Combating Corruption"

• Code of Administrative Offences of the Russian Federation (see Articles 19.28 "Illegal Remuneration on Behalf of a Legal Entity", 19.29 "Illegal Engagement of a State or Municipal Servant or Former State or Municipal Servant in Employment, Work, or Services")

• Criminal Code of the Russian Federation No. 63-FZ of 13.06.1996 (see Articles 290 "Receiving a Bribe", 291 "Giving a Bribe", 291.1 "Bribery Intermediation", 291.2 "Petty Bribery", 204 "Commercial Bribery", 204.1 "Intermediation in Commercial Bribery", 204.2 "Petty Commercial Bribery", 201 "Abuse of Authority", 285 "Abuse of Official Powers", 286 "Exceeding Official Powers", 304 "Provocation of a Bribe or Commercial Bribery")

• Federal Law No. 79-FZ of 07.05.2013 "On Prohibiting Certain Categories of Persons from Opening and Holding Accounts (Deposits), Storing Cash and Valuables in Foreign Banks Located Outside the Territory of the Russian Federation, and Owning and (or) Using Foreign Financial Instruments"

• Federal Law No. 172-FZ of 17.07.2009 "On Anti-Corruption Expert Review of Normative Legal Acts and Draft Normative Legal Acts"

• Federal Law No. 40-FZ of 08.03.2006 "On Ratification of the United Nations Convention against Corruption"

• Federal Law No. 125-FZ of 25.07.2006 "On Ratification of the Criminal Law Convention on Corruption"

• Federal Law No. 273-FZ of 25.12.2008 "On Combating Corruption"

• Federal Law No. 3-FZ of 01.02.2012 "On the Accession of the Russian Federation to the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions"

• Federal Law No. 230-FZ of 03.12.2012 "On Control over the Compliance of Expenses of Persons Holding State Positions and Other Persons with Their Income"

Normative Legal Acts of Foreign States with Extraterritorial Effect

• U.S. Foreign Corrupt Practices Act

• United Kingdom Bribery Act

• French Law "Sapin II" on Transparency, Anti-Corruption and Modernisation of the Economy

• Italian Law "Provisions on the Prevention and Combating of Corruption and Illegal Activities of Public Executive Authorities"

Decrees of the President of the Russian Federation

• Presidential Decree No. 378 of 29.06.2018 "On the National Anti-Corruption Plan for 2018–2020"

• Presidential Decree No. 650 of 22.12.2015 "On the Procedure for Notification by Persons Holding Certain State Positions of the Russian Federation, Federal State Service Positions, and Other Persons of the Occurrence of Personal Interest in the Performance of Official Duties that Leads or May Lead to a Conflict of Interest, and on Amendments to Certain Acts of the President of the Russian Federation"

• Presidential Decree No. 120 of 08.03.2015 "On Certain Issues of Combating Corruption"

• Presidential Decree No. 226 of 11.04.2014 "On the National Anti-Corruption Plan for 2014–2015"

• Presidential Decree No. 310 of 02.04.2013 "On Measures to Implement Certain Provisions of the Federal Law 'On Control over the Compliance of Expenses of Persons Holding State Positions and Other Persons with Their Income'"

• Presidential Decree No. 297 of 13.03.2012 "On the National Anti-Corruption Plan for 2012–2013 and Amendments to Certain Acts of the President of the Russian Federation on Anti-Corruption Issues"

• Presidential Decree No. 560 of 18.05.2009 "On the Submission by Citizens Applying for Managerial Positions in State Corporations, Funds, and Other Organisations, and by Persons Holding Managerial Positions in State Corporations, Funds, and Other Organisations, of Information on Income, Property, and Property-Related Obligations"

• Presidential Decree No. 460 of 13.04.2010 "On the National Anti-Corruption Strategy and the National Anti-Corruption Plan for 2010–2011"

• Presidential Decree No. 309 of 02.04.2013 "On Measures to Implement Certain Provisions of the Federal Law 'On Combating Corruption'"

• Presidential Decree No. 613 of 08.07.2013 "Issues of Combating Corruption"

• Presidential Decree No. 460 of 23.06.2014 "On Approval of the Form of the Statement of Income, Expenses, Property, and Property-Related Obligations, and Amendments to Certain Acts of the President of the Russian Federation"

• Presidential Decree No. 147 of 01.04.2016 "On the National Anti-Corruption Plan for 2016–2017"

Resolutions of the Government of the Russian Federation

• Government Resolution No. 228 of 05.03.2018 "On the Register of Persons Dismissed Due to Loss of Trust"

• Government Resolution No. 594 of 28.06.2016 "On Amendments to Certain Acts of the Government of the Russian Federation on the Prevention and Resolution of Conflicts of Interest"

• Government Resolution No. 568 of 05.07.2013 "On Extending to Certain Categories of Citizens the Restrictions, Prohibitions, and Obligations Established by the Federal Law 'On Combating Corruption' and Other Federal Laws for the Purpose of Combating Corruption"

• Government Resolution No. 613 of 22.07.2013 "On the Submission by Citizens Applying for Positions in Organisations Established to Fulfil Tasks Set Before the Government of the Russian Federation, and by Employees Holding Positions in Such Organisations, of Information on Income, Expenses, Property, and Property-Related Obligations, Verification of the Accuracy and Completeness of the Submitted Information, and Compliance by Employees with the Requirements for Official Conduct"

• Government Resolution No. 10 of 09.01.2014 "On the Procedure for Notification by Certain Categories of Persons of Receipt of a Gift in Connection with Protocol Events, Business Trips, and Other Official Events, the Participation in Which is Related to the Performance of Their Official (Job) Duties, the Handover and Evaluation of the Gift, Its Sale (Buyback), and the Crediting of Proceeds from Its Sale"

• Government Resolution No. 29 of 21.01.2015 "On Approval of the Rules for Notification by an Employer of the Conclusion of an Employment or Civil Law Contract for the Performance of Work (Provision of Services) with a Citizen Who Held State or Municipal Service Positions, the List of Which is Established by Normative Legal Acts of the Russian Federation"

FEEDBACK

If you become aware of the preparation or commission of corruption offences, you may report it:

FEEDBACK

Via email:

compliance@panelao.ru

By post:

Legal Support and Internal Control Department 5 Nizhny Susalny Lane, Bld. 15, Moscow, 105064, Russia

These communication channels are designed to receive reports from citizens regarding instances of corruption involving employees of PANELAO FM LLC, namely: abuse of official position, giving a bribe, receiving a bribe, abuse of authority, commercial bribery, or other unlawful use by an employee of their official position contrary to the legitimate interests of society and the state for the purpose of gaining benefits in the form of money, valuables, other property or property-related services, or other property rights for themselves or third parties, or the unlawful provision of such benefit to the said person by other individuals, as well as the commission of the said acts on behalf of or in the interests of PANELAO FM LLC.

Attention! Articles 128.1 (Defamation) and 306 (Knowingly False Report of a Crime) of the Criminal Code of the Russian Federation establish criminal liability for defamation and knowingly false report of a crime.

Anonymous reports and reports unrelated to instances of corruption involving employees of PANELAO FM LLC will not be considered.

Confidentiality is guaranteed during the receipt and review of reports, and no persecution of individuals who have reported instances of corruption in good faith is permitted.