The Anticorruption Policy of 'I`m Guide'

Large – scale legislative changes in the Russian Federation, which occurred in regulation of anticorruption activities of organizations, led to need to create in 2017 a single strategic document - the Anticorruption Policy of "I`m Guide" LLC (hereinafter - the Anticorruption Policy), which defined a common approach to implementation of article 13.3 Federal law of 25.12.2008 № 273-FZ "On combating corruption" requirements. They concern "I`m Guide" LLC on development and adoption of measures to prevent and combat corruption: identification and subsequent elimination of the causes of corruption (prevention of corruption); identification, prevention and suppression of corruption and other offenses; minimization and (or) elimination of the consequences of corruption and other offenses, including those provided for in article 19.28 Administrative Code "responsibility for illegal remuneration on behalf of a legal entity".

Anticorruption Policy is the fundamental document of "I`m Guide" LLC in the field of anti – corruption and contains: a set of interrelated principles and procedures, measures provided for by the act of official interpretation - Guidelines for the development and adoption of measures by organizations to prevent and combat corruption, developed by the Ministry of labor and social protection of the Russian Federation and approved on November 8, 2013.

The Anticorruption Policy is an element of the Company's internal control and risk management system, which provides for a set of measures aimed at preventing corruption, reducing corruption and reputation risks, as well as the risks of applying liability for bribery of officials to the Company.

The Goals of the Anticorruption Policy of "I`m Guide" LLC is to implement a unified approach to the requirements of article 13.3. Law on combating corruption, concerning the obligation of "I`m Guide" LLC to develop and take measures to prevent and combat corruption: the identification and subsequent elimination of the causes of corruption (prevention of corruption); identification, prevention and suppression of corruption and other offenses; minimization and (or) elimination of the consequences of corruption and other offenses.

The principles of anti-Corruption policy of LLC "I`m Guide" LLC include:

Compliance of the Anticorruption Policy with the current legislation and generally accepted norms.
Observance of legal rights and interests, protection of business reputation of employees, partners, contractors and other persons, observance of the trade secret regime in the implementation of anti-corruption measures.
A personal example of leadership in the formation of a culture of intolerance to corruption and the creation of an internal system of prevention and combating corruption.
Employee involvement: awareness of the organization's employees about the provisions of anti-corruption legislation and their active participation in the formation and implementation of anti-corruption standards and procedures.
Proportionality of anticorruption procedures to the extent of possible damage and the probability of corruption risk.
Effectiveness of anticorruption procedures: implementation of anticorruption measures that ensure ease of implementation and bring significant results.
Responsibility and inevitability of punishment for employees regardless of their position, length of service and other conditions in the case of corruption offenses in the performance of their duties.
Openness of business: informing partners, contractors, and the public about the adopted anticorruption standards of business.
Constant monitoring and regular monitoring of the effectiveness of the implemented anticorruption standards and procedures, as well as control of their implementation.

Objectives of Anticorruption Policy of "I`m Guide" LLC:

Identify key areas for implementation of the requirements of article 13.3. Anti-corruption law;
Create effective and Executive mechanisms for the implementation of measures to prevent and combat corruption (including the program of anticorruption measures);
To fix requirements and restrictions in cooperation with state bodies, which are competent to combat corruption;
To prevent corruption and other offenses, to ensure responsibility;
To form of the shareholders, partners, counterparties, members of management, employees have a clear understanding of the position of "I`m Guide" LLC of the rejection of corruption in all its forms and manifestations;
Minimize risks of involvement of "I`m Guide" LLC in corruption activities.

List of anticorruption measures has been developed and approved in "I`m Guide" LLC, which provides for the implementation of measures and procedures, the order of their implementation.

This Anticorruption Policy reflects the commitment of "I`m Guide" LLC high ethical standards of open and honest business to improve the corporate culture, follow the best practices of corporate governance and maintain the business reputation of the enterprise at the proper level.

You can find the full text of the Anticorruption Policy of "I`m Guide" LLC here

You can find the full text of the Code of corporate ethics of "I`m Guide" LLC here

Information on possible facts of corruption or suspicion of corruption in "I`m Guide" LLC can be reported:

by filling in the feedback form,
call by phone "Hot line about facts of corruption and fraud": +7 (495) 954 84 84,
by sending a written request to the address: 119311, Moscow, Vernadsky avenue, bld. 8А, office No. 15.