Anti-corruption policy

1. General Provisions

1.1. This Anti-Corruption Policy (hereinafter referred to as the “Policy”) is approved by LLC “RINAR-Automation” and applies to all its divisions, branches, representative offices, and projects, as well as to employees, contractors, suppliers, and any other persons acting on behalf of the Company.
1.2. The Policy has been developed in accordance with the legislation of the Russian Federation, including Federal Law No. 273-FZ “On Combating Corruption,” the Criminal Code of the Russian Federation, and other regulatory acts.
1.3. Compliance with this Policy is mandatory for all persons listed in Clause 1.1, regardless of their position or level of authority.
1.4. The Policy is published on the official website of the Company (rinar-automation.ru) and must be acknowledged by all employees against their signature.

2. Purpose and Objectives

2.1. The purpose of this Policy is to establish an effective system for the prevention, detection, and suppression of corruption risks in the Company’s operations.
2.2. The main objectives are to:

• Ensure compliance with anti-corruption legislation;

• Minimize corruption risks in all business processes (procurement, supply, contracting, customer relations, and interaction with government authorities);

• Increase the responsibility and legal awareness of employees and partners;

• Ensure transparency in decision-making in strategically important areas;

• Create safe channels for reporting corruption incidents (“hotline” mechanisms).

3. Principles

LLC “RINAR-Automation” is guided by the following principles in implementing this Policy:

• Legality – strict adherence to the laws of the Russian Federation;

• Zero tolerance for corruption – any form of bribery or abuse of power is strictly prohibited;

• Transparency and openness – key financial and contractual decisions must be documented and, where reasonable, open to internal control;

• Segregation of duties and responsibilities – prevention of excessive concentration of authority in one person without oversight;

• Accountability – violations of this Policy entail disciplinary, administrative, or criminal liability;

• Independence of control mechanisms – internal audit and compliance functions must operate independently and objectively.

4. Prohibited Activities

4.1. Employees, representatives, and contractors (acting on behalf of the Company) are prohibited from:

• Offering, giving, requesting, accepting, or facilitating the transfer of a bribe (in the form of money, goods, services, privileges, etc.);

• Using their position or influence for personal gain;

• Accepting gifts, services, or other benefits that could be perceived as influencing decision-making (except where expressly permitted by internal rules);

• Concealing or falsifying documents, reports, acts, estimates, invoices, or other accounting and operational data;

• Exerting unlawful influence on public officials to obtain favorable contracts or decisions.
  4.2. Transactions with counterparties where an employee or their relatives have a direct interest are strictly prohibited unless properly disclosed and approved (conflict of interest).

5. Conflict of Interest

5.1. A conflict of interest is a situation in which a person’s personal interests may affect, or appear to affect, their objectivity when making decisions in the interests of the Company.
5.2. An employee must immediately notify their supervisor or the designated compliance officer of any actual or potential conflict of interest.
5.3. Any person who reports a conflict of interest must be temporarily excluded from related decision-making until the conflict is resolved.
5.4. During procurement, contracting, and subcontracting, counterparties must be checked for links to employees, their relatives, or other affiliated persons.

6. Control and Procedures

6.1. Internal Control and Audit System

An internal control / compliance function is established to monitor adherence to this Policy, assess risks, and conduct inspections and investigations.
Internal audits of transactions are conducted periodically, with particular attention to procurement, major contracts, and supply of materials and equipment.
Special control is applied to transactions involving government or municipal customers.

6.2. Procurement, Contracts, and Subcontracting Procedures

• For procurements and contracts above the established internal threshold, a tender, competition, or quotation process is mandatory;

• The choice of supplier must be documented with protocols, evaluations, and comparison tables;

• Contracts with contractors having connections to employees are prohibited without prior verification and approval;

• All agreements must undergo legal review and be signed by authorized persons.

6.3. Due Diligence

• New counterparties must undergo mandatory reputation checks, including litigation history, debts, and affiliated entities;

• For government contracts, particular attention must be paid to verifying funding sources, licenses, and permits of contractors.

6.4. Training and Awareness

• All employees must complete anti-corruption training upon hiring and annually thereafter;

• Periodic notifications, reminders, and tests on Policy awareness and anti-corruption compliance are conducted;

• Access to the Policy is provided through internal portals and the Company website.

7. Reporting Channels and Whistleblower Protection

7.1. The Company establishes safe channels for reporting corruption (anonymous or identified):

• Email: info@rinar-automation.ru

• Trust line phone: +7 (495) 150 34 56

7.2. Reports are handled in strict confidentiality. The identity of the reporting person is not disclosed without their consent unless required by law.
7.3. Any form of retaliation, pressure, or discrimination against individuals who report corruption in good faith is strictly prohibited.

8. Liability

8.1. Violations of this Policy may result in disciplinary action (reprimand, dismissal) under the employment contract and internal regulations.
8.2. Where provided by law, administrative and criminal liability may also apply.
8.3. Managers at all levels who allow violations bear personal responsibility, which may include loss of signing authority, civil liability, and compensation for damages.

9. Monitoring, Review, and Effectiveness

9.1. This Policy shall be reviewed at least once every 2–3 years or upon changes in legislation, company structure, or scale of operations.
9.2. An annual report shall be prepared summarizing Policy implementation: number of reports received, audits conducted, violations identified, and measures taken.
9.3. Management must review the report and take corrective actions where necessary.

10. Final Provisions

10.1. This Policy is approved by the General Director of LLC “RINAR-Automation” and enters into force upon approval.
10.2. The Policy shall be acknowledged by all employees upon hiring and whenever updates are made.
10.3. The Policy is published on the official website rinar-automation.ru in the Corporate Documents section for public access.
10.4. In cases not covered by this Policy, the Company follows the applicable legislation of the Russian Federation and its internal regulations.

General Director
LLC “RINAR-Automation”