1.1. This Anti-Corruption Policy (hereinafter referred to as the "Policy") is a foundational document of VEGA-Ryazan LLC (hereinafter referred to as the "Organization"). It establishes key principles and requirements aimed at preventing corruption and ensuring compliance with applicable anti-corruption legislation by the Organization, its employees (hereinafter referred to as "Employees"), and other individuals acting on behalf of the Organization.
1.2. The Policy has been developed in accordance with the legislation of the Russian Federation, the Methodological Recommendations for the Development, and Implementation of Anti-Corruption Measures by Organizations (approved by the Ministry of Labor and Social Protection of the Russian Federation on November 8, 2013), the Code of Business Ethics, and other internal documents of the Organization.
1.3. The Policy is formulated with consideration that, under Russian law, "corruption," "corrupt practices," or "corrupt activities" include abuse of authority, commercial bribery, abuse of official position, offering or accepting bribes or any other illegal use by an individual of their official position contrary to the lawful interests of society and the state for personal gain (money, valuables, property, services, or other material benefits for themselves or third parties), or the illegal provision of such benefits.
1.4. Commercial bribery refers to the illegal transfer to a person performing managerial functions in a commercial or other organization of money, securities, other property, property-related services, or any other material rights, in exchange for actions (or inaction) in the interests of the giver, in connection with the recipient’s official position.
1.5. Abuse of authority refers to the use of managerial powers in a commercial or other organization contrary to its lawful interests, for the purpose of obtaining benefits (for oneself or others) or causing harm to others.
1.6. Conflict of interest refers to a situation where an Employee’s personal interest affects (or may affect) the proper performance of their duties, creating (or potentially creating) a contradiction between their personal interests and the Organization’s interests, which could harm the Organization’s property or business reputation.
1.7. Bribery refers to the giving or receiving (directly or through an intermediary) by a public official, foreign official, or official of an international organization of money, securities, property, property-related services, or other material benefits in exchange for actions (or inaction) within their official authority—or for general patronage or favoritism in their duties.
2.1. The Policy reflects the Organization’s commitment to open and honest business practices, the continuous improvement of corporate culture, adherence to best governance standards, and the maintenance of its business reputation.
2.2. The Organization aims to:
2.2.1. Minimize the risk of the Organization or its Employees (regardless of position) being involved in corrupt activities.
2.2.2. Ensure uniform understanding among partners, Employees, and other stakeholders of the Organization’s zero-tolerance stance toward corruption in any form.
2.2.3. Oblige Employees to comply with this Policy, key anti-corruption laws, and relevant prevention procedures.
2.2.4. Summarize and clarify core requirements of Russian anti-corruption legislation applicable to the Organization and its Employees.
3.1. All Employees must adhere strictly to this Policy.
3.2. The Organization’s Director is responsible for implementing the Policy, including appointing personnel to develop, enforce, and monitor anti-corruption procedures.
3.3. The Policy extends to partners, Employees, and other parties where contracts, internal documents, or laws impose corresponding obligations.
4.1. The Organization and Employees must comply with Russian anti-corruption laws, including the Criminal Code, the Administrative Offenses Code, the Federal Law "On Combating Corruption," which prohibits commercial bribery, offering or accepting bribes, bribery intermediation.
4.2. Key principles under the Federal Law "On Combating Corruption":
4.2.1. Ban on commercial bribery: Illegal receipt of money, property, or benefits by managers for actions/inaction in the giver’s interest.
4.2.2. Ban on abuse of authority: Using managerial powers against organizational interests for personal gain or to harm others.
4.2.3. Ban on bribery: Offering bribes (money, property, services) to officials for favorable actions/inaction or patronage.
4.2.4. Ban on accepting bribes: Officials receiving bribes directly/indirectly for undue favors.
4.2.5. Ban on bribing public officials: Providing undue advantages to influence official duties.
4.3. The Organization and Employees must comply with Russian anti-corruption laws and this Policy globally.
5.1 The Organization adheres to a zero-tolerance policy toward corruption in all forms, applying to daily operations, strategic projects, and interactions with partners, government officials, political parties, Employees, and other stakeholders.
5.2 The Organization identifies and periodically updates corruption risk indicators relevant to its activities and vulnerable business processes.
5.3 The Organization develops, implements, and monitors compliance with anti-corruption procedures.
5.4 The Organization takes reasonable steps to minimize risks of engaging with partners potentially involved in corrupt practices.
5.5 The Policy is publicly accessible on the corporate website. The Organization openly condemns corruption and encourages adherence to this Policy by all partners, Employees, and stakeholders.
5.6 The Organization monitors implemented anti-corruption procedures, ensures compliance, and revises/improves them as needed.
5.7 Employees face inevitable penalties for corruption violations, regardless of position or tenure. Senior management bears personal accountability for enforcing internal anti-corruption measures.
6.1 The Organization and Employees are prohibited from engaging agents, intermediaries, partners, joint ventures, or other parties to act in violation of this Policy or applicable anti-corruption laws.
7.1 Gifts, hospitality, or promotional expenses offered/received by Employees must meet all five criteria:
7.1.1 Directly tied to legitimate business purposes (e.g., project completion, contracts, national holidays).
7.1.2 Reasonable, proportionate, and not luxurious.
7.1.3 Must not constitute hidden rewards for favors, influence, or unethical/illegal purposes.
7.1.4 Pose no reputational risk if disclosed.
7.1.5 Comply with this Policy, the Code of Responsible Business Conduct, and applicable laws.
7.2 Cash gifts (in any currency or form) are strictly prohibited.
8.1 The Organization does not fund political parties, movements, or campaigns to gain commercial advantages in specific projects.
9.1 The Organization refrains from covering expenses (e.g., travel, accommodation, entertainment, PR) for public officials or their relatives to secure business advantages.
10.1 The Organization mandates all Employees to comply with this Policy, informing them of its principles, requirements, and sanctions for violations.
10.2 Secure, confidential, and accessible channels (e.g., an online feedback form at www.vega-ryazan.ru) are provided for reporting violations, including anonymous options.
10.3 New Employees sign anti-corruption policy acknowledgments, while existing staff undergo regular training on corruption prevention.
11.1 Anti-corruption clauses are included in contracts with intermediaries, partners, and agents, outlining compliance obligations and consequences for violations.
12.1 All financial transactions must be accurately recorded, detailed, and auditable.
12.2 Designated Employees are responsible for timely and truthful financial reporting under Russian law.
12.3 Falsifying accounting records is strictly prohibited.
13.1 Employees or third parties may report suspected violations without fear of retaliation via the website form (www.vega-ryazan.ru) or anonymously.
14.1 No Employee will face sanctions (e.g., dismissal, demotion) for refusing bribes or reporting corruption, even if it results in lost business opportunities.
15.1 Regular internal/external audits ensure compliance with this Policy, financial accuracy, and legal adherence.
15.2 Random checks validate payment legality, economic rationale, and documentation alignment with the Policy.
16.1 All Employees, regardless of position, are legally accountable for Policy violations or subordinates’ misconduct.
16.2 Violators may face disciplinary, administrative, civil, or criminal penalties under Russian law, organizational bylaws, or employment contracts.
To report corruption, use the form below or email: info@vega-ryazan.ru