Anti-corruption policy

In January 2013, Article 13.3 of Federal Law No. 273-FZ dated December 25, 2008 "On Combating Corruption" entered into force, establishing the obligation of an organization to take measures to prevent corruption.

Anti-Corruption and Commercial bribery Policy at Aikastoms Logistics LLC (hereinafter – the Policy) It reflects the commitment of the Company and its Management to high ethical standards and principles of open and honest business conduct, as well as the Company's desire to improve its corporate culture, follow the best practices of corporate governance and maintain the Company's business reputation at the appropriate level. The purpose of the anti-corruption system is to ensure that the Company's activities comply with the requirements of the anti-corruption legislation of the Russian Federation.

The main objectives of the anti-corruption system are:

creation of effective mechanisms, procedures, control and other measures aimed at combating corruption;
formation of intolerance to corrupt behavior among the Company's employees;
formation of a common understanding of the principles of the Policy among the Company's employees, customers, contractors, shareholders and others;
minimizing the risks of involving Company employees in corrupt activities;
informing the Company's management bodies about corruption offenses and measures taken in the framework of anti-corruption.

Policy Principles

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

recognition, provision and protection of fundamental human and civil rights and freedoms – corruption leads to violation of citizens' rights, to non-compliance with the conditions of legitimate competition between economic entities;
legality – The Company carries out its activities in accordance with the requirements of the legislation of the Russian Federation, which excludes the initiation and commission of corrupt actions by the Company;
publicity and openness of the activities of the Company's management bodies and employees (taking into account the requirements of the legislation of the Russian Federation on trade secrets);
responsibility and inevitability of punishment - Employees of the Company, regardless of their position, work experience and other conditions, are responsible for committing corruption offenses in connection with the performance of their work duties in accordance with the current legislation of the Russian Federation;
integrated use of managerial, organizational, informational, socio-economic, legal, special and other measures – the complexity of the use of anti-corruption measures is focused both on preventive work and on the direct fight against corruption and the elimination of their consequences;
priority application of measures to prevent corruption;
cooperation in the field of anti–corruption with government agencies, as well as partners and clients of the Company - The Company recognizes the general social nature of the problem of corruption and the need to combat corruption both through measures implemented within the framework of public policy and through the formation of intolerance to corruption on the part of society.

The Company adheres to the principle of non-acceptance of corruption in all forms and manifestations (the principle of "zero tolerance") in the implementation of daily activities and in the implementation of strategic projects, including in interaction with the Company's shareholders, with the Company's counterparties, with representatives of state and local governments, political parties, as well as other persons.

The Company makes the Policy freely available on the Company's official website on the Internet information and telecommunications network. The Company openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of the Policy by all contractors, members of management bodies and employees of the Company, and other persons. The Company imposes appropriate requirements on the Company's employees and candidates for employment in the Company for their non-involvement in corrupt activities.

Feedback

If you have become aware of information about corruption or other abuses in the Company, including unfair actions of employees and representatives of the Company, as well as if you have suggestions for improving anti—corruption procedures, please let us know - your information and assistance will help make our work more effective! Incoming information is sent confidentially to authorized compliance officers for subsequent analysis and verification.

You can contact directly with the management of the company or send a mail message to the address: 198035, St. Petersburg, nab. Fontanka River, 172, room 2, lit. A, room 19H, marked "for Security Management".