About RUSNANO Group

Anti-Corruption Policy

RUSNANO Anti-Corruption Policy provide guidance on how to conduct business in a fair, ethical and legal manner.

It is vital that we not only understand and appreciate the importance of our Policy but also comply with it in our daily work. Company’s reputation is our tomorrow.

The Policy provides information about anti-corruption applicable laws (including but not limited to the Law of the Russian Federation #273 “On Preventing Corruption, the FCPA and the Bribery Act) in order to avoid violations.

All associates of our company and our affiliate companies are required to read, understand and follow the precepts of our Company’s Code of Corporate Ethics, which includes anti-corruption expectations for all employees.

The Code of Corporate Ethics and the Policy guides our conduct, requiring honesty and integrity in all matters and circumstances, wherever we are.

The Company has hotline where any person (including employees, suppliers, partners, members of Board, citizens etc.) can report about violations, conflict of interest and others. The Rules of our Corporate Hotline Policy require protecting whistleblowers and providing confidentiality of messages.

Our anti-corruption compliance program consists of different procedures, monitoring controls, educational component and “Tone of the Top” procedure. Compliance officer of our Company conducts periodic reviews of the Compliance program regarding the anti-corruption laws. We conduct anti-corruption risk assessment every year.

We have due diligence program to screen suppliers, potential suppliers and other third parties. Our third parties aware about our Anti-Corruption Policy through anti-corruption clause. In addition, we use the right to audit procedures with our third parties.

Independent third parties perform audit of our anti-corruption compliance program to ensure compliance with applicable laws and the best practices.

Our Company is an active member of Anti-Corruption Charter of Russian business.