ANTI-CORRUPTION POLICY

Version of April 01, 2025

1. PURPOSE AND SCOPE

 

1.1. This Anti-Corruption Policy (hereinafter – the “Policy”) constitutes a set of interconnected principles, procedures, and specific measures aimed at the prevention and suppression of corruption offenses in the activities of UFO Hosting Limited Liability Company.

1.2. This Policy is mandatory for all employees of UFO Hosting LLC, whether under employment or civil law contracts, regardless of their position or functions performed.

2. GOALS AND OBJECTIVES OF THE ANTI-CORRUPTION POLICY

2.1. The goal of this Policy is to establish a unified approach to ensuring work on the prevention of and opposition to corruption within UFO Hosting LLC.
2.2. The objectives of this Policy are:

 

  • To inform employees about the legal and regulatory framework for combating corruption and the liability for committing corruption offenses;
  • To define the core principles of combating corruption at UFO Hosting LLC;
  • To develop and implement measures aimed at preventing and combating corruption at UFO Hosting LLC;
  • To declare the commitment of UFO Hosting LLC to the law and high ethical standards in business relations.

 

3. TERMS AND DEFINITIONS

3.1. Corruption – The abuse of an official position, giving a bribe, receiving a bribe, abuse of authority, commercial bribery, or 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 benefits in the form of money, valuables, other property, or services of a proprietary nature, or other property rights for oneself or for third parties, or the unlawful provision of such benefits to the said individual by other individuals. Corruption also includes the commission of the aforementioned acts on behalf of or in the interests of a legal entity.
3.2. Prevention of Corruption – The activities of UFO Hosting LLC aimed at introducing elements of corporate culture, organizational structure, rules, and procedures regulated by internal normative documents that ensure the prevention of corruption offenses, as well as the development of compliance in accordance with legal acts and best compliance practices.
3.3. Counterparty – Any Russian or foreign legal or natural person with whom UFO Hosting LLC enters into contractual relations, excluding employment relations.
3.4. 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 the unlawful provision of services of a proprietary nature or other property rights for performing actions (or inaction) in favor of the bribe-giver or the persons they represent, if such actions (or inaction) are within the official’s powers or if the official, by virtue of their position, can facilitate such actions (or inaction), as well as for general patronage or connivance in the line of duty.
3.5. Commercial Bribery – The unlawful transfer to a person performing managerial functions in a commercial or other organization of money, securities, other property, the provision of services of a proprietary nature, or the granting of other property rights for performing actions (or inaction) in the interests of the giver in connection with the official position held by that person.
3.6. Compliance – Ensuring the organization’s activities conform to the requirements imposed by Russian and foreign legislation, other mandatory regulatory documents, and creating mechanisms within the organization for analyzing, identifying, and assessing the risks of corruption-prone areas of activity and ensuring the comprehensive protection of UFO Hosting LLC.
3.7. Employee of UFO Hosting LLC – An individual working under an employment or civil law contract at UFO Hosting LLC.

4. LEGAL AND REGULATORY FRAMEWORK OF THIS POLICY

4.1. The fundamental legal act in the sphere of combating corruption in Russia is the Federal Law of December 25, 2008, No. 273-FZ “On Counteracting Corruption.” This Policy also considers foreign anti-corruption legislation, including the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), the UK Bribery Act of 2010, and the French Sapin II law.
4.2. This Policy is based on the international standard ISO 37001:2016 Anti-bribery management systems and the Methodological Recommendations for the development and adoption by organizations of measures to prevent and counteract corruption, approved by the Ministry of Labor and Social Protection of Russia on November 8, 2013.

5. DESIGNATION OF OFFICIALS RESPONSIBLE FOR THE IMPLEMENTATION OF THE ANTI-CORRUPTION POLICY

The key role in fostering a culture of intolerance towards corruption and in creating an internal system for preventing and combating corruption is assigned to the General Director of UFO Hosting LLC (“tone from the top”).
5.2. The General Director of UFO Hosting LLC acts as the guarantor of the implementation of anti-corruption rules and procedures within the organization.

6. CORE PRINCIPLES OF ANTI-CORRUPTION ACTIVITIES AT UFO HOSTING LLC

Combating corruption at UFO Hosting LLC is based on the following principles:

6.1. Principle of Conformity with Applicable Law: This Policy is subject to regular monitoring for compliance with the anti-corruption legislation of the Russian Federation, as well as the U.S. FCPA and the UK Bribery Act.
6.2. Principle of Leadership by Example (Tone from the Top): The key role of UFO Hosting LLC’s management in fostering a culture of intolerance towards corruption is assigned to its leadership team.
6.3. Principle of Employee Involvement: This Policy is published on the website https://ufo.hosting/. Employee training is conducted on the following topics:
 

  • Corruption in the public and private sectors;
  • Legal liability for committing corruption offenses;
  • Familiarization with legal requirements and internal documents of UFO Hosting LLC on combating corruption;
  • Conduct in situations of corruption risk, particularly in cases of extortion of bribes;
  • Interaction with law enforcement agencies on matters of preventing and combating corruption.

 

Individual confidential consultations on anti-corruption matters are available to employees upon request to management.
6.4. Principle of Proportionality: The development and implementation of measures are based on an assessment of existing corruption risks in the Company’s activities.
6.5. Principle of Effectiveness: UFO Hosting LLC strives to implement anti-corruption procedures that are simple to execute and yield significant results. All employees have access to anti-corruption policies, and familiarization is mandatory.
6.6. Principle of Accountability and Inevitability of Punishment: The Company adheres to the principle of inevitable punishment for employees who commit corruption offenses, regardless of their position.
6.7. Principle of Business Transparency: This Policy is publicly available. Furthermore, UFO Hosting LLC includes an anti-corruption clause in its contracts to inform counterparties of its zero-tolerance policy towards corruption.
6.8. Principle of Continuous Monitoring and Control: Management is responsible for regularly monitoring the effectiveness of implemented anti-corruption standards and procedures.

7. RIGHTS AND OBLIGATIONS OF EMPLOYEES AND THE COMPANY RELATED TO CORRUPTION PREVENTION

7.1. UFO Hosting LLC values fair, lawful, and ethical conduct among employees.
7.2. Employees may use this Policy to obtain information about anti-corruption regulations and their responsibilities.
7.3. An employee must:

 

 

  • Refrain from committing or participating in corruption offenses;
  • Avoid behavior that could be interpreted as a willingness to engage in corruption;
  • Immediately inform their direct supervisor or management of any attempts to induce them to commit corruption offenses;
  • Immediately report any known instances of corruption by other employees, counterparties, or other persons;
  • Report any potential or actual conflict of interest to their direct supervisor or management.

 

7.4. Any report related to a violation of this Policy can be made personally to a supervisor or via email. The Company guarantees protection against retaliation and confidentiality.

8. LIST OF IMPLEMENTED ANTI-CORRUPTION MEASURES, STANDARDS, AND PROCEDURES

8.1. UFO Hosting LLC assesses the existence of a counterparty’s anti-corruption policy during its due diligence process.
8.2. The Company implements the following measures:
8.2.1. Adoption and implementation of this Anti-Corruption Policy.
8.2.2. Inclusion of an anti-corruption clause in contracts with counterparties.
8.2.3. A procedure to protect employees who report corruption from formal and informal sanctions.
8.2.4. Periodic assessment of corruption risks.
8.2.5. Individual counseling for employees on anti-corruption standards.
8.2.6. Regular monitoring of compliance with internal procedures.
8.2.7. Regular control of accounting records and the accuracy of primary documents.
8.2.8. Regular control of the economic justification of expenses in high-risk areas (gifts, entertainment, etc.).
8.2.9. Regular evaluation of the results of anti-corruption efforts.

9. LIABILITY FOR NON-COMPLIANCE WITH THE ANTI-CORRUPTION POLICY

9.1. The liability of UFO Hosting LLC for violating anti-corruption legislation is stipulated in the Code of Administrative Offenses of the Russian Federation.
9.2. Employees of UFO Hosting LLC bear criminal, administrative, civil, and disciplinary liability (up to and including termination) for committing corruption offenses.

10. CORRUPTION RISK ASSESSMENT

10.1. Corruption risk assessment is a critical element of this Policy.
10.2. It is recommended to conduct a corruption risk assessment at least once a year.
10.3. The assessment includes internal control procedures as outlined in Section 12.

11. IDENTIFICATION AND RESOLUTION OF CONFLICTS OF INTEREST

11.1. Identifying conflicts of interest is a key method of preventing corruption.
11.2. To manage and prevent conflicts of interest, UFO Hosting LLC conducts ongoing work with employees and has adopted this Policy.

12. INTERNAL CONTROLS

12.1. Management is responsible for exercising internal control over business operations.
12.2. The objectives of internal control are to ensure the reliability of financial reporting and compliance with legal and internal regulations, including this Policy.
12.3. Control over the documentation of business operations is aimed at preventing and detecting violations such as unofficial reporting, use of forged documents, recording non-existent expenses, etc.
12.4. The economic justification of business gifts, entertainment expenses, charitable donations, and consultant fees must be verified.
12.5. Attention should be paid to red flags, such as:
 

  • Payment for vaguely defined services;
  • Providing lavish gifts or entertainment to external consultants or government officials;
  • Fees to intermediaries that exceed market rates;
  • Suspicious cash payments.
  • Purchases or sales at prices significantly different from market prices;

 

13. ANTI-CORRUPTION MEASURES IN INTERACTIONS WITH COUNTERPARTIES

13.1. UFO Hosting LLC values business relationships with organizations that demonstrate integrity, high ethical standards, and their own anti-corruption measures.
13.2. The Company has implemented special counterparty due diligence procedures to reduce corruption risks, focusing on reputation, market history, and involvement in corruption scandals.
13.3. Provisions on compliance with anti-corruption standards shall be included in contracts with counterparties.
13.4. This Policy is published on the official website https://ufo.hosting/.

14. INTERACTION WITH GOVERNMENT BODIES EXERCISING OVERSIGHT FUNCTIONS

14.1. Employees of UFO Hosting LLC must refrain from any illegal or unethical conduct when interacting with government officials conducting inspections.
14.2. The Company prohibits giving anything of value (gifts, money, loans, services, entertainment, etc.) to government officials in connection with their official duties.

15. COOPERATION WITH LAW ENFORCEMENT AGENCIES

15.1. Cooperation with law enforcement agencies includes:

 

 

  • Assisting authorized representatives during inspections related to anti-corruption;
  • Assisting in the investigation of corruption crimes.

 

15.2. Employees must support the investigation of corruption by preserving and providing relevant documents and information.
15.3. Management must be involved in preparing responses to law enforcement inquiries.
15.4. Employees must not interfere with the official duties of judicial or law enforcement officers.

16. PROCEDURE FOR REVIEWING AND AMENDING THE POLICY

16.1. The implementation of this Policy is subject to regular effectiveness monitoring.
16.2. This Policy may be revised in other cases, such as changes in the Labor Code of the Russian Federation or anti-corruption legislation.