Version 1 dated 01.03.2020

ANTI-CORRUPTION POLICY

1. Purpose of the document. General provisions.

1.1. This Anti-Corruption Policy (hereinafter referred to as "The Policy") is drafted in order to protect the rights and freedoms of citizens, to enforce law, order and public safety, and is a local document of Desktop LTD, that defines the key principles and requirements aimed at corruption prevention and compliance with anti-corruption legislation by management, employees and other persons who may act on behalf of Desktop LTD.

 1.2. This Policy is drafted in accordance with the Federal Law №273-FZ, dated 25.12.2008, "On Countering Corruption", "Guidelines for organizations for development and adoption of measures to prevent and combat corruption " of the Ministry of Labor and Social Protection of Russian Federation dated 08.11.2013 .  

1.3. Anti-corruption measures of Desktop LTD are aimed at:
1.3.1. Prevention of corruption, including identification and subsequent elimination of corruption reasons; 

 1.3.2. Identification, prevention, suppression, solving and investigation of corruption offenses (fight against corruption); 

1.3.3. Minimization and (or) elimination of the consequences of corruption offenses. 

2. Definitions used in this Policy

2.1. In this Policy the following definitions are used:

 Corruption is acceptance by Desktop LTD employees in their own interests or in interest of other persons, personally or through intermediaries, of material benefits, as well as gaining advantages, using their official powers and related opportunities, as well as bribing these persons by individuals and legal entities by unlawfully providing them with the above specified benefits and advantages; 

 Anti-corruption policy is the activities of Desktop LTD, aimed at creating an effective system of fighting against corruption; 

 Corruption offense is an act that has characteristics of corruption, for which a regulatory legal act imposes civil, disciplinary, administrative or criminal liability;

 Prevention of corruption - the activities of Desktop LTD within anti-corruption policy aimed at identifying, studying, limiting or eliminating the phenomena causing corruption offenses or contributing to their spreading;

 Conflict of interest is a situation in which a personal interest directly or indirectly influences or may influence the proper fulfilment of his official duties and cause or may cause contradiction between employee’s personal interest and rights, and the legitimate interests of citizens, organizations, society or the state capable of causing harm to the rights and legitimate interests of citizens, organizations, society and the state.

 Employee’s personal interest is the employee’s ability to receive for himself or for third parties income in the form of money, valuables, or other property or material services, other property rights when performing his duties. 

 Employees - are individuals who are in the employ of the organization on the basis of labour contracts.

 Notification – employee’s message to the organization about the fact of being addressed for the purpose of inducing to commit corruption offences.

 Counterparty - any Russian or foreign legal or physical person with whom the organization enters into contractual relations, except for employment relations.

 Bribe - receipt by an official body personally or through an intermediary of money, securities, other property or in the form of illegal provision of property services to him, provision of other property rights for the commission of actions (inactions) in favour of the briber or persons represented by him if such actions (inactions) shall be within the official 's duties or if, by virtue of the official position, he may contribute to such actions (inactions), as well as for general protectorship or connivance in his duty. 

 Corrupt payment - illegal transfer to a managerial person in a commercial or other organization, of money, securities, other property, provision to him of a property nature services, of other property rights for the commission of actions (inactions) in the interests of the bribing person in connection with his managerial position.  

3. Purposes of this Policy

3.1. Desktop LTD has the following purposes: 

3.1.1. To minimize the risk of involving the organization, management and employees regardless of their position, in corruption activities; 

 3.1.2. To summarize and explain the basic requirements of the anti-corruption legislation of Russian Federation, which can be applied to Desktop LTD and its employees; 

 3.1.3. To impose employees to be aware of and to comply with the principles and requirements hereof , the key standards of applicable anti-corruption legislation, as well as to implement adequate measures to prevent corruption. 

4. Principles of this Policy

4.1. All employees of Desktop LTD should be guided hereby and strictly follow its principles and requirements. 

 4.2. The General Director of Desktop LTD is responsible for the organization of all activities aimed at implementation of the principles and requirements hereof , including the appointment of persons responsible for the development, implementation and control of anti-corruption measures. 

 4.3. The principles and requirements hereof apply to counterparties and representatives of Desktop LTD, as well as to those persons with whom the corresponding obligations are stipulated in contracts, in internal documents or directly result from the legislation. 

 4.4. The General Director of Desktop LTD forms the ethical standard of an irreconcilable attitude to any forms and manifestations of corruption, setting an example by his behavior and making all the employees and counterparties aware of the anti-corruption policy.

 4.5. When creating a system of countermeasures, Desktop LTD should follow the key principles for fighting against corruption: 

 4.5.1. The principle of compliance of the organization’s work with current legislation and generally accepted standards. Compliance of implemented anti-corruption measures with the Constitution of Russian Federation, the legislation of Russian Federation and other regulatory legal acts applicable to the organization.

 4.5.2. The principle of managers’ personal example. The key role of managers of the organization in expressing intolerability to corruption and in creation of a corporate system of preventing and combating corruption. 

 4.5.3. The principle of employees’ involvement. Awareness of employees about anti-corruption legislation and their active participation in formation and implementation of anti-corruption standards and procedures. 

 4.5.4. The principle of proportionality between the anti-corruption procedures and the risk of corruption. Development and implementation of a set of measures to reduce the probability of involving the organization, its head and employees in corruption activities, is carried out taking into account the corruption risks existing in the organization’s operations. 

 4.5.5. The principle of effectiveness of anti-corruption procedures. The usage of such anti-corruption measures, which are of low cost, provide ease of implementation and bring significant results. 

 4.5.6. The principle of responsibility and inevitability of punishment. The inevitability of punishment for employees, regardless of their position, length of service and other circumstances in case of their committing corruption offenses in connection with their labor duties, as well as the personal responsibility of the managers for the implementation of the corporate anti-corruption policy. 

 4.5.7. The principle of continuous control and regular monitoring. Regular monitoring of the effectiveness of the implemented anti-corruption standards and procedures, as well as control under their implementation. 

5. Anti-corruption legislation

5.1. DESKTOP LTD, including all the employees, must comply with norms of Russian anti-corruption legislation, established, inter alia, by the Criminal Code of Russian Federation, the Code of Administrative Offenses of Russian Federation, Federal Law “On Countering Corruption”, this Policy and other regulatory acts the main requirements of which are the prohibition of bribery, the prohibition of accepting bribes, the prohibition of corrupt payment and the prohibition of mediation in bribery. 

 5.2. That being said, all employees of DESKTOP LTD are strictly prohibited directly or indirectly, personally or through third parties, to get engaged in corrupt activities, to offer, to give, to promise, to ask and to receive bribes or to make payments to simplify administrative, bureaucratic and other formalities in any form, including in the form of cash, valuables, services or other benefits, to any persons and from any persons or organizations, including commercial organizations, authorities and self-government organizations, public officers, private companies and their representatives. 

6. Exchange of business gifts and signs of business hospitality. Representational expenses.

6.1. Business gifts and signs of business hospitality should:  

- comply with the requirements of the anti-corruption legislation of Russian Federation, local regulatory acts of the organization, this Policy; 

 - be given only on behalf of the organization; 

 - be directly related to the legal objectives of DESKTOP LTD or national holidays (New Year, 8th of March, 23th of February, etc.) and suitable to the financial condition of the organization; 

 - be reasonable, adequate and not a luxury item. The cost of a gift may not exceed 3,000.00 (three thousand) rubles (clause 1 of Art. 575 of the Civil Code of Russian Federation); 

 - be acquired by agreement with the general director of DESKTOP LTD; 

 - not be a hidden reward for a service, action, inaction, connivance, patronage, granting rights, making a certain decision about any deal, agreement, permission, etc. or an attempt to influence the recipient with any other illegal or unethical purpose; 

 6.2. Business gifts and signs of business hospitality should not: 

- create obligations for the recipient related to his official position or his performance of official duties; 

 - represent a hidden reward for a service, an action or inaction, connivance or patronage, granting rights or certain decisions, or an attempt to influence the recipient with any other illegal or unethical purpose;

 - be in the form of cash, non-cash money, securities, precious metals; 

 - create reputational risk for DESKTOP LTD, employees and other persons in case of disclosure of information about gifts or hospitality expenses; 

 - be handed over or received from government officials or government representatives, politicians or political parties. 

 6.3. Employees are allowed to receive business gifts, signs of business hospitality only at official events, if this does not contradict the requirements of the anti-corruption legislation of Russian Federation, these Policy, and local regulatory acts of the organization. 

 6.4. When receiving a business gift or signs of business hospitality, an employee is obliged to take measures to prevent a conflict of interest in accordance herewith, other local regulatory acts of the organization.  

6.5. In a conflict of interest or the possibility of it is arising out of receipt of a business gift or signs of business hospitality, an employee is required to notify in writing the official responsible for combating corruption in accordance with the procedure for disclosure of the conflict of interest. 

 6.6. Employees of Desktop LTD are prohibited:

 - to accept offers from organizations or third parties about giving business gifts and signs of business hospitality, to receive business gifts and signs of business hospitality on business negotiations, when concluding contracts, as well as in other cases where such actions may influence or create an impression that they may influence on the decisions making process; 

 - to request, demand, force organizations and third parties to give them or their relatives business gifts and / or provide signs of business hospitality in their favor;

- to accept gifts in the form of cash, non-cash money, securities, precious metals. 

 6.7. An employee who received a business gift that does not comply with clauses 6.1, 6.2 hereof must inform director about it and hand him over the business gift. 

7. Participation in charity events and sponsor activities

7.1. Desktop LTD may decide on participation in charity events and sponsorship activities in proportion to the financial standing. At the same time, the budget and the plan for participation in the event and activities are approved by DESKTOP LTD General Director.

8. Interaction with goverment officials

8.1 DESKTOP LTD does not pay, independently or through its employees, any expenses (monetary remuneration, loans, services, entertainment, transportation costs and other remuneration) for civil servants and their close relatives (or in their interests) in order to obtain or retain advantages for the organization in commercial activities. 

 8.2. Employees are solely responsible for the corruption when interacting independently with government officials in accordance with the current legislation of Russian Federation.   

9. Interaction with employees

9.1. DESKTOP LTD requires its employees to comply with these Policy, informing them of the key principles, requirements and sanctions for violations. 

 9.2. DESKTOP LTD arranges safe, confidential and handy means of communication with the management (a written statement addressed to the head or to the person responsible for compliance with the anti-corruption policy or personal appeal; telephone or facsimile messages; e-mail) about the bribery from those who render service in interests of the organization or on its behalf. Proposals for the improvement of anti-corruption measures and control, as well as inquiries from employees and third parties can be sent to the general director of Desktop LTD. 

 9.3. To form an appropriate level of anti-corruption culture, an introductory briefing regarding this Policy and related documents is held with new employees, and the regular informational events are held for existing employees.

 9.4. In DESKTOP LTD the following duties for employees related to the prevention and combating corruption are fixed: 

- refrain from committing and / or participating in commission of corruption offenses in the interests or on behalf of the organization; 

 - refrain from behavior that can be interpreted by others as willingness to commit or participate in commission of a corruption offense in the interests or on behalf of the organization;

 - immediately inform the manager or the person responsible for compliance with the anti-corruption policy, the management of DESKTOP LTD, about cases of employee incitement to commit corruption offenses; 

 - immediately inform the manager or the person responsible for compliance with the anti-corruption policy, the management of DESKTOP LTD, about information on cases of corruption offenses committed by other employees, counterparties of the organization or other persons that became known to the employee; 

 - inform the manager or other responsible person about the possibility of a conflict of interest the employee may have. 

 9.5. In case the employee is addressed in order to induce him to commit corruption offenses, he is obliged to immediately notify the employer verbally. Within one working day the employee must send a written notification. If it is impossible to send a notification within a specified time (in case of illness, travel, vacation, etc.), the employee shall send a notification to the employer within one working day after arriving at the workplace; 

 9.6. The notification should contain the following information: 

- surname, name, patronymic of the applicant, contact phone number, as well as other information that, in the opinion of the applicant, will help to establish contact with him; 

- job title; 

- circumstances in which the appeal to induce to commit corruption offenses occurred; 

- information available about the legal entity or individual, who made an appeal to induce to commit corruption offenses; 

- statement of the appeal (date and place of the appeal, the action (inaction) to commission of which the appeal was inclined to, the proposed benefit, the intended consequences, other circumstances of the appeal);

 - information about the persons involved in the case, and witnesses, if any;

 - information about addressing to the prosecution authorities or other state bodies about the appeal to induce to commit corruption offenses (if any); 

 - other known information of interest for the proceedings on the merits; 

- applicant’s signature; 

- date of the notification. 

 9.7. The employer considers the notification and sends it to the official responsible for combating corruption in the organization on the day he received the notice. Anonymous notifications are transmitted to the official responsible for combating corruption in the organization, for information. 

 9.8. Verification of the information contained in the notification is made within 15 business days from the date of the notification receipt. 

 9.9. In order to organize the inspection, the official responsible for combating corruption within three working days creates a commission to check the fact of the appeal to induce the employee to commit corruption offenses. 

 9.10. The members of the commission (chairman, deputy chairman, members and secretary of the commission) are appointed and approved by the order of General Director of Desktop LTD. 

 9.11. During the inspection the following facts should be determined: 

- the reasons and conditions that contributed to the person's appealing to an employee to incite him to commit corruption offenses,

 - the actions (inactions) of the employee to the illegal execution of which the third party tried to incite him. 

9.12. The results of the inspection are submitted to the employer in the written conclusion within three days after the inspection ends. The conclusion shall indicate: 

- member list of the commission; 

- inspection terms; 

 - applicant’s name and the circumstances that gave rise to the inspection; 

 - confirmation of the validity (or invalidity) of the fact that gave rise to filing of the notification; 

- reasons and circumstances that gave rise to the appeal to induce the employee to commit corruption offenses; 

- conclusions and recommended measures. 

 9.13. In case the fact of appealing to induce the employee to commit corruption offenses is confirmed, the commission makes recommendations to the employer on the implementation of measures to prevent corruption offenses. The employer makes a decision concerning filing of information to the prosecution authorities. 

 9.14. If the fact of appealing to induce an employee to commit corruption offenses is not confirmed, but during the inspection there appeared signs of violations of requirements for corporate behavior or conflict of interest, the materials collected during the inspection, as well as the conclusion shall be sent for general director’s consideration to decide whether to take disciplinary action regarding the respective employee, within two business days after completion of the inspection. 

10. Interaction with intermediaries and other persons, counterparties verification 

10.1. DESKTOP LTD selects counterparties for rendering services based on the following principles: 

 - equality, fairness, non-discrimination and lack of unreasonable restrictions on competition in relation to counterparties; 

 - honest and reasonable choice among the most preferred offers; 

 - targeted and cost-effective spending of money on the purchase of goods and services (including, if necessary, the cost of the life cycle of the purchased products) and the implementation of measures aimed at reducing company costs; 

 - prevention of corruption, conflict of interests and other abuses of authority. 

 10.2. DESKTOP LTD aims to have business relationships with counterparties that comply with the requirements of anti-corruption legislation and / or counterparties that declare the rejection of corruption. 

10.3. DESKTOP LTD declares that it refuses to stimulate employees of counterparties in any way, including by providing monetary funds, gifts, donating works (services) to them and other ways not mentioned here, making the counterparty employee conditioned and aimed at ensuring that this employee performs any actions the organization will benefit from.  

11. Information sharing and training

11.1. DESKTOP LTD posts this Policy available on the official website on the Internet, openly declares opposition to corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all counterparties, its employees and other persons. 

 11.2. DESKTOP LTD contributes to raising the level of anti-corruption culture by informing and systematically training employees in order to maintain their awareness of the company's anti-corruption policies and mastering the ways and techniques of applying anti-corruption policies in practice. 

12. Anti-corruption measures

12.1. Desktop LTD practices the following anti-corruption measures:

 - development and approval of Code of ethics and corporate behavior of employees; 

- appointment of officials responsible for prevention of corruption and other offenses; 

- conducting anti-corruption expertise on concluded contracts, 

- informing the employer by the employees about cases of inclining them to commit corruption offences; 

 - informing the employer about details that became known to the employee, about cases of corruption offenses committed by other employees, counterparties of the organization or other persons; 

- informing the employer about arising of a conflict of interest; 

- conducting training activities aimed at preventing and combating corruption; 

- cooperation with law enforcement authorities. 

13. Cooperation with law enforcement authorities in respect of combating corruption

13.1. Cooperation with law enforcement authorities is an important indicator of the actual adherence of DESKTOP LTD to the declared anti-corruption standards of behavior. 

This cooperation can be carried out in various forms: 

 - need to report to the relevant law enforcement authorities about corruption offenses that have become known in the organization; 

- assistance to authorized representatives of control and supervisory and law enforcement authorities in conducting inspections of the organization’s activities aimed at preventing and combating corruption; 

 - assistance to authorized representatives of law enforcement authorities in carrying out activities aimed at disrupting or investigating of corruption crimes, including criminal intelligence and surveillance operations; 

 - management and employees of the organization should not interfere in processing of official duties by judicial or law enforcement authorities. 

14. Measures of prevention and settlement of conflict of interests

14.1. The management of conflict of interest in DESKTOP LTD is based on the following principles: 

- mandatory disclosure of information about real or potential conflict of interest; 

 - individual consideration and assessment of reputational risks for the organization while identification of each conflict of interest and its settlement; 

 - confidentiality of the disclosure of conflict of interest and the process of its settlement; 

 - observance of the balance of interests between the organization and the employee in settlement of conflicts of interest; 

- protection of the employee from prosecution connected with the information about the conflict of interest, which was promptly disclosed by the employee and settled (prevented) by the enterprise. 

 14.2. This Policy stipulates the following duties of employees connected to the disclosure and settlement of conflicts of interest: 

- an employee of DESKTOP LTD must take measures to prevent any possibility of a conflict of interest; 

- when making decisions on business issues and performing his duties to be guided by the interests of the organization without taking into account their personal interests, the interests of their relatives and friends; 

 - to avoid situations and circumstances that could lead to a conflict of interest; 

- to disclose a real or potential conflict of interest; 

-to assist to the settlement of a conflict of interest. 

 14.3. The following types of disclosure of conflicts of interest are used in DESKTOP LTD: 

- disclosure of information about a conflict of interest when applying for a job, 

- disclosure of information about a conflict of interest when transferring to a new position;

 - disclosure of information of conflict of interest as it occurs, etc. 

 14.4. An employee must notify his manager in writing about the conflict of interest that occurred or about the possibility of its occurrence as soon as he becomes aware of this. The consideration of information submitted and the settlement of conflicts of interest should be confidential. The received information should be thoroughly checked by an authorized official to evaluate the seriousness of the risks involved and the selection of the most appropriate form of settlement of conflict of interest. 

 14.5. DESKTOP LTD may come to the conclusion that the situation, the information about which was provided by the employee, is not a conflict of interests and, as a result, does not need special ways of settlement. 

 14.6. DESKTOP LTD may also come to the conclusion that there is a conflict of interests and use different ways to resolve it , including: 

 - restriction of employee’s access to specific information; 

- voluntary refusal of the employee or his deprivation (permanent or temporary) from participation in the discussion and decision-making process on issues that are or may be affected by a conflict of interest; 

 - revision and change of functional duties of the employee; 

- temporary deprivation of an employee from his office, if his personal interests conflict with functional duties; 

 - transfer of an employee to a position which implies the performance of functional duties that are not related to a conflict of interest; 

- transfer by the employee of his property on which the conflict of interest may be based on to trust management; 

 - refusal of the employee from his personal interest, generating a conflict with the interests of the organization; 

 - dismissal of the employee from the organization on the initiative of the employee;

- dismissal of the employee on the initiative of the employer for the disciplinary offense, that is for non-fulfillment or improper fulfilment of his duties due to his fault. 

 The abovementioned list of methods to settle conflicts of interest is not exhaustive. In each specific case, by agreement between DESKTOP LTD and the employee who discloses information about a conflict of interest, other forms of settlement may be used. 

 14.7. The official responsible for combating corruption is responsible for receiving information about a conflict of interest arising (existing). 

 14.8. Consideration of the received information is carried out by committee . The committee shall issue written recommendations to the interested parties to resolve the conflict of interest not later than after seven working days. 

 14.9. If a member of the committee and an interested person is the same person, such member shall not participate in the discussion of a conflict of interest. If head of the organization is involved in a conflict of interest, he also shall not participate in decision making on this issue. 

 14.10. This Policy is not aimed at describing all possible conflicts of interest that may arise. It should be used in any situation when the personal interest of the employee contradicts the interests of DESKTOP LTD. 

15. Responsibility for nonfulfillment (improper fulfillment) of this Policy

15.1. The manager and employees of all divisions of Desktop LTD, regardless of their position, according to the current legislation of Russian Federation, are responsible for observing the principles and requirements of this Policy, as well as for the actions (inactions) of their subordinates who violate these principles and requirements. 

 15.2. Persons guilty of violating the requirements of this Policy may be brought to disciplinary, administrative, civil or criminal liability on the initiative of Desktop LTD, law enforcement authorities or other persons in the manner and on the grounds provided for by the legislation of Russian Federation, local regulations and labor contracts. 

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