Anti-Corruption Policy of LLC "Mosanka"

1. General Provisions

This Anti-Corruption Policy (hereinafter — the "Anti-Corruption Policy") is a local regulatory act of Limited Liability Company "Mosanka" (hereinafter — the "Organization"), which defines the key principles and requirements aimed at preventing corruption and ensuring compliance with applicable anti-corruption legislation by employees and other persons who may act on behalf of the Organization.

The Anti-Corruption Policy has been developed in accordance with Federal Law No. 273-FZ of December 25, 2008, "On Combating Corruption," and other regulatory legal acts of the Russian Federation.

Key Terms and Definitions

Corruption — abuse of official position, giving a bribe, receiving a bribe, abuse of authority, commercial bribery, or any other unlawful use by an individual of their official position contrary to the legitimate interests of society and the state, for the purpose of obtaining a benefit in the form of money, valuables, other property, or property-related services, or other property rights, for themselves or for third parties, or the unlawful provision of such a benefit to said individual by other individuals. Corruption also includes the commission of the listed acts on behalf of or in the interests of a legal entity.

Combating corruption — the activities of federal government authorities, government authorities of constituent entities of the Russian Federation, local self-government bodies, civil society institutions, organizations, and individuals within their powers:

a) to prevent corruption, including the identification and subsequent elimination of the causes of corruption (corruption prevention);

b) to detect, prevent, suppress, investigate, and solve corruption offenses (fight against corruption);

c) to minimize and/or eliminate the consequences of corruption offenses.

Corruption prevention — the activities of the Organization, its officials, and employees aimed at fostering corporate culture, creating an organizational structure, and establishing rules and procedures that ensure the prevention of corruption offenses.

Corruption offense — an unlawful, culpable act (action or omission) possessing the characteristics of corruption, for which disciplinary, criminal, civil, or administrative liability is established by law.

Corruption risks — the risks of a corruption offense being committed by an official, employee, representative of the Organization, or any other person acting on behalf of and/or in the interests of the Organization.

Anti-corruption clause — a section of the Organization's contracts that establishes the obligations of the parties to prevent the commission of corruption offenses in the performance of the contract and liability for failure to fulfill said obligations.

Anti-Corruption Policy of the Organization — a set of interrelated principles, procedures, and specific measures aimed at preventing and combating corruption in the Organization.

Anti-corruption obligations — the agreement of an official/employee/representative/contractor of the Organization to comply with and implement the principles and requirements of the Anti-Corruption Policy, including the obligation not to commit corruption or other offenses.

Contractor (Counterparty) — any Russian or foreign legal entity or individual with whom the Organization enters into contractual relations, excluding employment relations.

Bribe — the receipt by an official, a foreign official, or an official of a public international organization, personally or through an intermediary, of money, securities, other property, or unlawful provision of property-related services or other property rights, for performing actions (or omission) in favor of the bribe-giver or the persons they represent, if such actions (or omission) fall within the official's authority or if, by virtue of their official position, they can facilitate such actions (or omission), as well as for general patronage or connivance in service.

Commercial bribery — the unlawful transfer to a person performing managerial functions in a commercial or other organization of money, securities, other property, as well as the unlawful provision of property-related services or other property rights (including when, at the direction of such person, property is transferred, property-related services are rendered, or property rights are granted to another individual or legal entity) for performing actions (or omission) in the interests of the giver or other persons, if such actions (or omission) fall within the official authority of such person or if, by virtue of their official position, they can facilitate such actions (or omission).

Conflict of interest — a situation in which the personal interest (direct or indirect) of a person holding a position that requires them to take measures to prevent and resolve a conflict of interest influences or may influence the proper, objective, and impartial performance of their official (employment) duties (exercise of authority).

Personal interest of an official/employee/representative of the Organization — the possibility of receiving income in the form of money, other property, including property rights, property-related services, results of work performed, or any benefits (advantages) by the official/employee/representative of the Organization, and/or persons closely related to them by kinship or affinity (parents, spouses, children, brothers, sisters, as well as brothers-in-law, sisters-in-law, parents-in-law, children of spouses, and spouses of children), citizens, or organizations with whom the official/employee/representative of the Organization, and/or persons closely related to them by kinship or affinity, are connected by property, corporate, or other close relations.

2. Goals and Principles of the Anti-Corruption Policy

2.1. The Anti-Corruption Policy reflects the Organization's commitment to high ethical standards and the principles of open and honest interaction, as well as its aspiration to improve corporate culture, follow best practices of corporate governance, and maintain its business reputation at a high level.

2.2. The main goals of the Anti-Corruption Policy are:

1. minimizing the risk of involvement of officials, employees, representatives, and contractors of the Organization, regardless of their position, in corruption offenses;
2. fostering among officials, employees, representatives, and contractors of the Organization a uniform understanding of the Anti-Corruption Policy regarding the non-acceptance of corruption in any form or manifestation;
3. establishing the obligation of officials, employees, representatives, and contractors of the Organization to know and comply with the key provisions of anti-corruption legislation and the applicable requirements of the Anti-Corruption Policy.

2.3. The Anti-Corruption Policy of the Organization is based on the following principles:

2.3.1. Principle of non-acceptance of corruption in any form or manifestation.

2.3.2. Principle of compliance of the Anti-Corruption Policy with current legislation and generally accepted norms.

This Anti-Corruption Policy complies with the Constitution of the Russian Federation, international treaties concluded by the Russian Federation, the legislation and other regulatory legal acts of the Russian Federation applicable to the Organization.

2.3.3. Principle of personal example of leadership.

The key role of the Organization's leadership in shaping a culture of zero tolerance for corruption and in creating an internal system for preventing and combating corruption.

2.3.4. Principle of employee awareness and involvement.

Employees of the Organization are regularly informed about the provisions of anti-corruption legislation and actively participate in the development and implementation of anti-corruption standards and procedures.

2.3.5. Principle of proportionality of anti-corruption procedures to corruption risk.

The Organization develops and implements measures that reduce the likelihood of the Organization, its officials, employees, representatives, and contractors being involved in corrupt activities.

2.3.6. Principle of effectiveness of anti-corruption procedures.

The Organization applies anti-corruption measures that are simple to implement and produce meaningful results.

2.3.7. Principle of accountability and inevitability of punishment.

Inevitability of punishment for officials/employees/representatives of the Organization, regardless of their position, length of service, or other conditions, in the event of their committing corruption offenses, as well as the personal responsibility of the Organization's leadership for the implementation of the internal Anti-Corruption Policy.

2.3.8. Principle of continuous control and regular monitoring.

The Organization regularly monitors the effectiveness of implemented anti-corruption standards and procedures and exercises control over their execution.

3. Scope of the Anti-Corruption Policy

3.1. The primary persons subject to the Anti-Corruption Policy are officials and employees of the Organization in employment relations with it, regardless of their position and functions. The Anti-Corruption Policy also applies to persons acting on behalf of the Organization under a Power of Attorney (representatives) and to persons performing work or providing services for the Organization under civil-law contracts.

3.2. Obligations of officials/employees/representatives of the Organization regarding the prevention and combating of corruption:

1. not to commit or participate in the commission of corruption offenses;
2. to refrain from behavior that could be interpreted by others as an intention or readiness to commit or participate in the commission of a corruption offense;
3. to promptly inform the person responsible for the prevention of corruption offenses in the Organization, or to immediately report to the "Hotline" on anti-corruption matters:

1. to inform the person responsible for the prevention of corruption offenses in the Organization about the possibility of a conflict of interest arising for an official/employee/representative of the Organization, or about an existing conflict of interest.

3.3. The Organization's leadership shall foster an ethical standard of zero tolerance for any form or manifestation of corruption at all levels, setting an example through their own conduct.

3.4. The principle of non-acceptance of corruption in any form or manifestation is established in the Organization.

3.5. Periodic risk assessment. The Organization identifies, reviews, and evaluates the corruption risks characteristic of its activities as a whole and of individual areas.

3.6. The Organization develops and implements anti-corruption procedures.

3.7. The Organization brings the Anti-Corruption Policy to the attention of its employees against signature, publishes it in open access on its official website, openly declares its non-acceptance of corruption, and welcomes and encourages compliance with the principles and requirements of the Anti-Corruption Policy by all employees and other persons.

The Organization promotes the advancement of anti-corruption culture through information and systematic training of employees in order to maintain their awareness of Anti-Corruption Policy matters.

4. Gifts and Business Expenses

4.1. Gifts that officials/employees/representatives may provide on behalf of the Organization to other persons and organizations, or that officials/employees/representatives may receive from other persons and organizations in connection with their work at the Organization, as well as business expenses, including expenses for business hospitality and promotion of the Organization that employees and other persons may incur on behalf of the Organization, must simultaneously meet the following criteria:

1. be directly related to the legitimate purposes of the Organization's activities;
2. be reasonably justified, proportionate, and not constitute luxury items;
3. not create reputational risks for the Organization's employees and other persons in the event of disclosure of information about the gifts or business expenses;
4. not contradict the principles and requirements of federal legislation, the Anti-Corruption Policy, and other local acts of the Organization.

4.2. Gifts on behalf of the Organization, its officials, employees, or representatives to third parties in the form of cash or non-cash monetary funds, or their equivalent in any form, are not permitted.

4.3. To account for the provision of gifts on behalf of the Organization by officials/employees/representatives to third parties and the receipt of gifts by officials/employees/representatives from third parties, the Organization may maintain relevant gift registries and appoint a person responsible for keeping such registries.

5. Participation in Charitable Activities

The Organization does not finance charitable projects for the purpose of obtaining commercial advantages.

6. Participation in Political Activities

The Organization does not finance political parties, organizations, and movements, or individual political figures, for the purpose of obtaining commercial advantages or general patronage.

7. Interaction with Government and Municipal Officials

7.1. The Organization refrains from paying any expenses for government and municipal officials of the Russian Federation, officials of international organizations, and their close relatives (or in their interests) for the purpose of obtaining commercial advantages or general patronage, including expenses for transportation, accommodation, meals, entertainment, advertising, or any other benefit received at the Organization's expense.

7.2. Officials/employees/representatives of the Organization must refrain from any offers the acceptance of which may place a government or municipal official in a conflict of interest situation.

7.3. The Organization takes measures aimed at preventing its being held administratively liable on the grounds provided for in Article 19.28 of the Code of Administrative Offenses of the Russian Federation, including, among other things, a ban on:

1. the transfer, offer, or promise, on behalf of and in the interests of the organization, to a government or municipal official, an official, a person performing managerial functions in a commercial or other organization, a foreign official, or an official of a public international organization, of money, securities, other property, the provision of property-related services, or the granting of property rights for the performance (or omission) of an act in the interests of said official related to their official position;
2. the offer, transfer, or attempted transfer of gifts to officials exercising government (municipal) control or state supervision, where the giving of such gifts is prohibited by applicable legislation.

7.4. The Organization has established a procedure for reporting to law enforcement authorities facts of violations of the requirements for the official conduct of government and municipal officials during control and supervisory activities in relation to the Organization.

8. Interaction with Officials, Employees, and Representatives

8.1. The Organization requires its officials, employees, representatives, and persons performing work or providing services for it under civil-law contracts to comply with the Anti-Corruption Policy, informing them of the key principles, requirements, and sanctions for its violation.

8.2. The Organization ensures safe, confidential, and accessible means for officials/employees/representatives to inform the Organization's management and/or the person responsible for the prevention of corruption offenses in the Organization about facts of corrupt behavior by third parties. The Organization welcomes suggestions for improving anti-corruption procedures and controls.

8.3. Any employee of the Organization or other person, in case of concern or doubt about the legality of their own actions, or the actions/omissions of other employees, officials, representatives, contractors, or other persons interacting with the Organization, may report their concern or doubt to their immediate supervisor or to the person responsible for the prevention of corruption offenses in the Organization.

9. Interaction with Third Parties

9.1. The Organization and its officials/employees/representatives are prohibited from engaging or using intermediaries, partners, contractors, agents, or other persons to perform any acts that contradict the principles and requirements of the Anti-Corruption Policy or the norms of applicable anti-corruption legislation.

9.2. The Organization ensures the availability of procedures for checking intermediaries, partners, contractors, agents, and other persons to prevent and/or detect the violations described above, in order to minimize and suppress the risks of the Organization's involvement in corrupt activities.

9.3. For the purpose of implementing the principles and requirements set forth in the Anti-Corruption Policy, the Organization includes anti-corruption conditions (clauses) in contracts with intermediaries, partners, contractors, agents, and other persons.

Anti-corruption conditions (clauses) must contain information on the general principles and anti-corruption procedures that the parties must comply with, and define the liability of contractors for non-compliance with the principles and requirements of the Anti-Corruption Policy.

10. Waiver of Retaliatory Measures and Sanctions

The Organization declares that no employee/representative will be subjected to sanctions (including dismissal, demotion, or deprivation of incentive payments) if they have reported suspected or known actions/omissions of any employees of the Organization or other persons interacting with the Organization that contradict anti-corruption legislation or the provisions of the Anti-Corruption Policy, including, among other things, cases where such employee/representative has refused to give or receive a bribe, commit commercial bribery, or act as an intermediary in bribery.

11. Review of Information on Corruption Offenses and Other Violations of the Anti-Corruption Policy

The person responsible for the prevention of corruption in the Organization ensures the review and thorough verification of information about existing or suspected facts of corruption offenses or other violations of the provisions of the Anti-Corruption Policy that the Organization receives through any channels of communication, including information obtained as a result of internal control or external audit of the Organization.

The Organization implements the necessary procedures, adopts the necessary local regulatory acts, and empowers the persons conducting the verification with all the necessary authority and resources, including independence from any other officials and divisions of the Organization, to conduct such verifications.

In accordance with the rules and procedures determined by the Organization, the results of such verifications are brought to the attention of and reviewed by the Organization's management, and based on the results of such review, decisions are made to ensure compliance with the requirements of the Anti-Corruption Policy (including, for example, decisions to improve measures for the prevention and combating of corruption in the Organization, and to apply disciplinary liability measures to persons who have committed corruption offenses).

12. Anti-Corruption Analysis

The Organization ensures the conduct of anti-corruption analysis of draft local regulatory acts and existing local regulatory acts of the Organization in order to exclude the risks of establishing preconditions for corruption offenses.

13. Audit and Control

13.1. The Organization conducts internal audit of its financial and economic activities, control over the completeness and correctness of data reflected in accounting records, and compliance with the requirements of applicable legislation and internal regulatory documents, including the principles and requirements established by the Anti-Corruption Policy.

13.2. As part of internal control procedures, the Organization conducts reviews of key areas of activity, including spot checks of the legality of payments made, their economic justification, and the appropriateness of expenses, including verification by primary accounting documents and compliance with the requirements of the Anti-Corruption Policy.

14. Persons Responsible for the Implementation of the Anti-Corruption Policy

14.1. The person responsible for the implementation of the Anti-Corruption Policy is the head of the Organization / director.

The person responsible for the implementation of the Anti-Corruption Policy is obliged to ensure compliance with the requirements of current anti-corruption legislation and the local regulatory acts of the Organization aimed at implementing measures to prevent corruption.

14.2. The person responsible for the implementation of corruption prevention measures in the Organization is the executive director, responsible for the prevention of corruption offenses, who:

1. organizes the work on the prevention and combating of corruption in the Organization in accordance with the Anti-Corruption Policy;
2. organizes the development of draft local regulatory acts aimed at implementing the list of anti-corruption measures determined by the Anti-Corruption Policy and submits them for approval to the Organization's management.

14.3. The Organization adopts the necessary local regulatory acts and implements the necessary administrative, technical, and other measures to ensure the independent activities of the person responsible for the prevention of corruption offenses in the Organization.

15. List of Implemented Anti-Corruption Measures, Events, Standards, and Procedures

Corruption prevention measures include:

• issuance of local regulatory acts of the Organization aimed at implementing measures to prevent corruption (on conflict of interest; official conduct; regulating the exchange of business gifts, reports on the employment of former government (municipal) officials, etc.);
• monitoring the effectiveness of the measures taken;
• inclusion of a standard anti-corruption clause in contracts related to financial, economic, and procurement activities (e.g., "I undertake not to violate anti-corruption legislation," etc.);
• introduction of a procedure for employees to inform their employer about instances of being solicited to commit corruption offenses, about information known to the employee regarding instances of corruption offenses committed by other employees, contractors of the organization, or other persons, and the procedure for reviewing such reports;
• conducting corruption risk assessments to identify areas of activity most exposed to such risks and developing corresponding anti-corruption measures;
• organizing procedures for checking intermediaries, partners, contractors, and other persons to prevent and/or detect the violations described above in order to minimize and suppress the risks of the Company's involvement in corrupt activities;
• familiarizing employees, against signature, with local and regulatory legal acts governing the requirements in the field of prevention and combating of corruption offenses;
• conducting training events on the organization of work in the field of combating corruption;
• posting and updating information on anti-corruption on the official website of the Organization on the Internet and on information boards in the administrative buildings of the Organization's office and divisions.

16. Liability of Officials/Employees/Representatives of the Organization for Non-Compliance with the Requirements of the Anti-Corruption Policy

16.1. Officials/employees/representatives of the Organization, regardless of their position, bear liability as provided for by the legislation of the Russian Federation for non-compliance with the principles and requirements of the Anti-Corruption Policy, as well as for the actions (omissions) of their subordinates that violate these principles and requirements.

16.2. Measures of liability for corruption offenses in the Organization include criminal, administrative, disciplinary, civil, and material liability measures in accordance with current legislation and local acts of the Organization.

17. Cooperation with Law Enforcement Agencies in the Field of Combating Corruption

17.1. Cooperation with law enforcement agencies is an important indicator of the Organization's commitment to the declared anti-corruption standards of conduct.

17.2. The Organization undertakes a public commitment to:

1. report to law enforcement agencies instances of corruption and other offenses that have become known to the Organization;
2. refrain from any sanctions against its officials and employees who have reported to law enforcement agencies information about the preparation or commission of a corruption or other offense that became known to them in the course of performing their official duties;
3. not allow unlawful interference by officials/employees/representatives of the Organization in the activities of law enforcement agencies during anti-corruption measures.

17.3. The Organization assists law enforcement agencies in conducting inspections of the Organization's activities on matters of prevention and combating of corruption.

18. Procedure for the Revision and Amendment of This Policy

This Policy may be revised and amended in the event of:

• changes in current legislation;
• changes in the requirements imposed on the Organization;
• insufficiently effective provisions of the anti-corruption policy or related anti-corruption procedures;
• additions, proposals, or appendices to specify certain aspects of the anti-corruption policy.

LLC "Mosanka" — Anti-Corruption Policy — Approved by Order No. 31-P dated 03.09.2026