I. Introduction

This Code has been approved by the Board of Directors of “Russian investments” GC (hereinafter referred to as the “Group”). The Code was introduced in view of the fact that formation, strengthening and protection of goodwill of the Group as a bona fide and fair structure operating in accordance with moral, ethical and legal rules, is one of priorities of activity of the Group.

This document contains a summary of basic ethical principles of Group operation. Separate provisions of the Code, ethical principles and their application shall be considered in more detail in the additional governing documents of the Group, standards, regulations, provisions, job descriptions, etc.

II. Ethical values of the Company

Official motto of the Group: Honor above benefit! Honor lucro altior est!

The Group especially appreciates:

  • Respect of personal rights and interests of our employees and partners, customer requirements and terms of cooperation, which are put forward by our business partners and the company.
  • Impartiality that presumes labour remuneration according to the achieved results and granting equal rights for professional growth.
  • Honesty in relations and in providing of any information necessary for our work.
  • Efficiency as steady achievement of the greatest possible results in everything that we do.
  • Courage to resist something that is unacceptable, taking on responsibilities for the consequences of our decisions.
  • Constancy and consistency in observance of any business liability undertaken by the Group or its responsible officers.
  • Trusting in our employees, which lets us delegate powers and liability for decisions and methods of their fulfillment.
  • Observance of the current legislation and respect for the government authority not only from the Group, but also from its employees.
  • Patriotism to the interests of the Homeland, activity for the benefit of building of progress, authority and welfare of the Russian Federation and its citizens.

Observance of these values will allow us to maintain and develop the corporate culture which is necessary for achievement of the highest level in all our business aspirations. Our values find their reflection in our success. We do not relinquish our values for the sake of profit earning. We consider these values as an interlink of all fields of our business activity and we expect the same in our relations with business partners.

III. Basic ethical principles

For implementation of its ethical values, the Group observes ethical principles, which cover five main areas:

  • Employees
  • Relations with third parties and clients
  • Relations with public authorities
  • Safety, health and environment protection
  • Efficiency, control and reporting

Employees

In its relations with Employees, the Group complies all requirements of the labor law and conditions of the employment agreement, respects personal freedoms and human rights, grants everyone equal opportunities and does not allow discrimination in employment, it never employs child labor in its businesses.

The Group observes confidentiality and guarantees personal data protection for its Employees.

The Employees:

  • are not entitled to engage in other activity, which is seriously distracting or preventing them from fulfillment of their employment duties,
  • must act only in the interests of the Group and avoid any conflicts of interest,
  • cannot implement transactions with securities on the basis of insider information
  • must not accept from third parties any gifts, services or entertainments, which might be interpreted as bribery

Relations with third parties and clients

The Group is focused on creation of mutually beneficial relations with third parties and clients based on the principles of partnership and mutual respect. The Group:

  • is governed by needs of Clients and aspires to guarantee high quality of its products and services,
  • always fulfills its obligations and expects proper discharge of obligations by its partners,
  • operates with observance of legislation on counteraction of legalization of illegally received monies (money laundering),
  • conducts business only with partners who are engaged in legal business activity and whose financial sources are legal,
  • does not accept any form illegal payments and does not apply unethical or unfair methods of impact on its partners or competitors.

Relations with public authorities

The Group is focused on creation and maintenance of solid official relations with state bodies, in accordance with laws and other regulations. The Group:

  • does not make any attempts to illegally influence decisions of state bodies or their representatives and executives,
  • follows all laws and requirements applicable to its activity, and remains true both to the letter, and to spirit of the laws,
  • pays taxes in full and within the established deadlines,
  • does participate in work of political parties neither directly, nor indirectly.

Safety, health and environment protection

The Group performs everything necessary to contain and mitigate accidents and industrial injuries. The Group aspires for full compliance with all officially approved environmental standards and requirements and fully realizes the need of development of environmentally safe production facilities:

  • efficient use of natural resources;
  • development and applications of resource-saving and non-waste technologies;
  • introduction of modern environmental management systems and ISO standards in all enterprises of the Group.

All Employees bear liability for fulfillment of requirements of safety, health and environment protection in all activities of the Group.

Efficiency, control and reporting

The Group is focused on optimum use of resources which are at its disposal, and also analyzes the risks connected with its activity and manages such risks for achievement of goals set by it executives.

The Group adheres to the principle of transparency and high standards of planning, control and reporting and focuses on ensuring safety of its assets, which includes business information.

IV. Observance of requirements of the Code

Each Employee of the Group is obliged to observe requirements of the Code and bears liability for personal ethical behavior. Violation of the Code entails application to the violator of penalties established by the CEOs of the companies – members of the Group, the law and other statutory regulations.