ANTI-CORRUPTION POLICY

1. Purpose of the document. General provisions.

1.1. Current Provision "On Anti-Corruption Policy" (hereinafter referred to as "Provision") was developed in order to protect the rights and freedoms of citizens, to ensure law, order and public safety, and is a Desktop LTD local document, that defines the key principles and requirements aimed at corruption prevention and implementation of anti-corruption laws, guidelines, employees and other persons who may act on behalf of Desktop LTD.

1.2. This provision was developed in accordance with the Federal Law №273-FZ, dated 25.12.2008, "On Combating Corruption", "Guidelines for the development and adoption of measures to prevent and combat corruption by organizations" of the Ministry of Labor and Social Protection of the Russian Federation.

1.3. Anti-corruption measures of Desktop LTD are aimed at:
- prevention of corruption, including the identification and subsequent removal of the causes of corruption (prevention of corruption);
- identification, prevention, suppression, disclosure and investigation of corruption offenses (fight against corruption);
- minimization and (or) elimination of the consequences of corruption offenses.

2. Basic definition of the Provision

2.1. In this provision the following basic definitions are used:

Corruption is acceptance by Desktop LTD employees in their own interests or in interest of other persons, personally or through intermediaries, of material benefits, as well as gaining advantages, using their official powers and related opportunities, as well as bribing these persons by individuals and legal entities unlawfully providing them with of the specified benefits and advantages;

Anti-corruption policy is the activities of Desktop LTD, aimed at creating an effective system to fight against corruption;

Corruption offense is an act that has characteristics of corruption, for which a regulatory legal act imposes civil, disciplinary, administrative or criminal liability;
Corruption factor is a phenomenon or a combination of phenomena causing corruption offenses or contributing to their spread.

Prevention of corruption - the activities of Desktop LTD on anti-corruption policies aimed at identifying, studying, limiting or eliminating the phenomena causing corruption offenses or contributing to their spread;

Conflict of interest is a situation in which a personal interest directly or indirectly influence or may influence the proper discharge of official duties and cause or may cause the contradiction between employee’s personal interest and rights, and the legitimate interests of citizens, organizations, society or the state capable of to cause harm to the rights and legitimate interests of citizens, organizations, society and the state, that can cause harm to the rights and legitimate interests of citizens, organizations, society and the state.

Employee’s personal interest is the employee’s ability to receive for himself or for third parties income in the form of money, valuables, or other property or material services, other property rights when performing his duties.

3. Purposes of the Provision

3.1. The provision reflects the commitment of DESKTOP LTD and its management to high ethical standards and the principles of open delivery of information about the services provided, work performed, tariffs established for the organization, as well as the desire of DESKTOP COMPANY to improve corporate culture, to follow the best practices of corporate management and to support business reputation of the organization at the proper level.

3.2. Desktop LTD has the following goals:
- to minimize the risk of involving the organization, management and employees (employees), regardless of their position, in corruption activities;
- to summarize and explain the basic requirements of the anti-corruption legislation of the Russian Federation, which can be applied to Desktop LTD and employees;
- to charge employees to be aware of and to comply with the principles and requirements of this Provision, key standards of applicable anti-corruption legislation, as well as to implement an adequate measures to prevent corruption.

4. Provision principles

4.1. All the Desktop LTD employees should be guided by this Provision and strictly follow its principles and requirements.

4.2. The General Director of Desktop LTD is responsible for the organization of all activities aimed at implementation of the principles and requirements of this Provision, including the appointment of persons responsible for the development, implementation and control of anti-corruption measures.

4.3. This Provision’s principles and requirements apply to counterparties and representatives of Desktop LTD, as well as to those persons the corresponding obligations of who are stipulated in contracts, in their internal documents or directly result from the law.

4.4. The Desktop General Director forms the ethical standard of an irreconcilable attitude to any forms and manifestations of corruption, setting an example by his behavior and making all the employees and counterparties aware of the anti-corruption policy.

4.5. When creating a system of countermeasures, Desktop LTD should follow the key principles for fighting against corruption:
4.5.1. The principle of compliance of the organization’s work with current legislation and generally accepted standards. Compliance of implemented anti-corruption measures with the Constitution of the Russian Federation, the legislation of the Russian Federation and other regulatory legal acts applicable to the enterprise.
4.5.2. The principle of managers’ personal example. The key role of managers of the organization in building a culture of intolerability to corruption and in creation of a corporate system of preventing and combating corruption.
4.5.3. The principle of employee involvement. Awareness of employees of the organization about the provisions of anti-corruption legislation and their active participation in the formation and implementation of anti-corruption standards and procedures.
4.5.4. The principle of proportionality between the anti-corruption procedures and the risk of corruption. Development and implementation of a set of measures to reduce the probability of involving the organization, its manager and employees in corruption activities, is carried out taking into account the corruption risks existing in the organization’s operations.
4.5.5. The principle of the effectiveness of anti-corruption procedures. The usage of such anti-corruption measures at the enterprise, which are of low cost, provide ease of implementation and bring significant results.
4.5.6. The principle of responsibility and inevitability of punishment. The inevitability of punishment for employees of the organization, regardless of their position, length of service and other circumstances in the case of their committing corruption offenses in connection with the performance of labor duties, as well as the personal responsibility of the managers of the organization for the implementation of the corporate anti-corruption policy.
4.5.7. The principle of continuous control and regular monitoring. Regular monitoring of the effectiveness of the implemented anti-corruption standards and procedures, as well as control under their implementation.

5. Anti-corruption legislation

5.1. DESKTOP LTD, including all the employees, must comply with the Russian anti-corruption legislation, established, inter alia, by the Criminal Code of the Russian Federation, the Code of Administrative Offenses of the Russian Federation, the Federal Law “On Combating Corruption”, this Provision and other regulatory acts the main requirements of which are the prohibition of bribery, the prohibition of accepting bribes, the prohibition of commercial bribery and the prohibition of mediation in bribery.

5.2. In the light of the foregoing, all employees of DESKTOP LLC are strictly prohibited, directly or indirectly personally or through third parties, to engage in corrupt activities, to offer, to give, promise, to ask and to receive bribes or to make payments to simplify administrative, bureaucratic and other formalities in any form , including in the form of cash, valuables, services or other benefits, to any persons and from any persons or organizations, including commercial organizations, authorities and self-government organizations, public officers, private companies and their representatives.

6. Exchange of business and signs of business gifts and signs of business hospitality. Representational expenses.

6.1. Business gifts and signs of business hospitality should: <br>- comply with the requirements of the anti-corruption legislation of the Russian Federation, local regulatory acts of the organization, this Provision.
- be given only on behalf of the organization.
- be directly related to the legal objectives of the DESKTOP LTD or national holidays (New Year, the 8th of March, the 23th of February, etc.) and suitable to the financial condition of the organization;
- to be reasonable, proportionate and not a luxury item. The cost of a gift may not exceed 3,000.00 (three thousand) rubles (clause 1 of Art. 575 of the Civil Code of the Russian Federation);
- be acquired in agreement with the general director of DESKTOP LTD;
- not to be a hidden reward for a service, action, inaction, connivance, patronage, granting rights, making a certain decision about a transaction, agreement, permission, etc. or an attempt to influence the recipient with a different illegal or unethical purpose;

6.2. Business gifts and signs of business hospitality should not:
- create obligations for the recipient related to his official position or his performance of official duties;
- represent a hidden reward for a service, an action or inaction, connivance or patronage, the granting of rights or certain decisions, or an attempt to influence the recipient with a different illegal or unethical purpose;
- be in the form of cash, non-cash money, securities, precious metals;
- do not create reputational risk for DESKTOP LTD, employees and other persons in case of disclosure of information on gifts or representative expenses;
- should not be served or received from government officials or government representatives, politicians or political parties.

6.3. Employees of an organization may receive business gifts, signs of business hospitality only at official events, if this does not contradict the requirements of the anti-corruption legislation of the Russian Federation, these Provision, and local regulatory acts of the organization.

6.4. When receiving a business gift or signs of business hospitality, an employee of an organization is obliged to take measures to prevent the possibility of a conflict of interest in accordance with this Provision, other local regulatory acts of the organization.

6.5. In case of a conflict of interest or the possibility of a conflict of interest connected to the receipt of a business gift or signs of business hospitality, an employee of an organization is required to notify in written form the structural unit or official of the organization responsible for combating corruption in accordance with the procedure for disclosure of the conflict of interest.

6.6. Employees of the organization are prohibited:
- to accept offers from organizations or third parties on the giving business gifts and signs of business hospitality, business gifts and signs of business hospitality on business negotiations, when concluding contracts, as well as in other cases where such actions may influence or create an impression that they can influence on the decisions making process;
- to request, demand, force organizations and third parties to give them or their relatives business gifts and / or provide signs of business hospitality in their favor;
- to accept gifts in the form of cash, non-cash money, securities, precious metals.

6.7. An employee of an organization who has received a business gift that does not comply with clause 6.1, clause 6.2 of this Provision is obliged to inform about it and hand over the business gift to his supervisor.

7. Participation in charity events and sponsor activities

7.1. Desktop LTD can decide on participation in charity events and sponsorship activities in proportion to the financial health of the organization. At the same time, the budget and the plan for participation in the event and activities are approved by the DESKTOP’s General Directory.

8. Interaction with goverment officials

8.1 DESKTOP LTD does not pay, independently or through its employees, any expenses (monetary remuneration, loans, services, entertainment, transportation costs and other remuneration) for civil servants and their close relatives (or in their interests) in order to obtain or retain advantages for the organization in commercial activities.

8.2. Employees of the organization are solely responsible for the corruption when interacting independently with government officials in accordance with the current legislation of the Russian Federation.

9. Interaction with imployees

9.1. DESKTOP LTD requires its employees to comply with these Provision, informing them of the key principles, requirements and sanctions for violations.

9.2. In DESKTOP LTD, safe, confidential and accessible means of informing the management of the organization are organized (a written statement addressed to the head or to the person responsible for compliance with the anti-corruption policy or personal appeal; telephone or facsimile messages; e-mail) about the bribery be those who render service in interests of a commercial organization or on its behalf. Proposals for the improvement of anti-corruption measures and control, as well as inquiries from employees and third parties can be sent to the director general of the organization.

9.3. To form an appropriate level of anti-corruption culture, an introductory briefing on these Provision and related documents is held with new employees, and the regular informational events are held for existing employees.

9.4. In DESKTOP LTD the following duties of workers are fixed, related to the prevention and combating of corruption:
Refrain from committing them and / or participating in the commission of corruption offenses in the interests or on behalf of the organization;
- refrain from behavior that can be interpreted by others as a willingness to commit or participate in the commission of a corruption offense in the interests or on behalf of the organization;
- immediately inform the direct manager or the person responsible for compliance with the anti-corruption policy, the management of DESKTOP LTD, about cases of employee incitement to commit corruption offenses;
- immediately inform the direct manager or the person responsible for compliance with the anti-corruption policy, the management of DESKTOP LTD, about information about cases of corruption offenses committed by other employees, counterparties of the organization or other persons that became known to the employee;
- inform the direct manager or other responsible person about the possibility of a conflict of interest the employee can have.

9.5. In the case the employee of the organization receives the appeal in order to induce him to commit corruption offenses, the said employee of the organization is obliged to immediately verbally notify the employer. Within one working day, the employee of the organization is obliged to send a written notification. <br>If it is impossible to send a notification within a specified time (in the case of illness, travel, vacation, etc.), the employee of the organization sends a notification to the employer within one working day after arriving at the workplace;

9.6. The notification should contain the following information: <br>- surname, name, patronymic of the applicant, contact phone number, as well as other information that, in the opinion of the applicant, will help to establish contact with him;
- replaceable position;
- the circumstances in which the appeal occurred in order to induce to commit corruption offenses;
- the known information about the legal entity or individual, who made an appeal in order to induce to commit corruption offenses;
- a statement of the nature of the appeal (the date and place of the appeal, the action (inaction) to commission of which the appeal incline to, the proposed benefit, the intended consequences, other circumstances of the appeal);
- information about the persons involved in the case, and witnesses, if any;
- information about informing the prosecution authorities or other state bodies about the appeal in order to induce to commit corruption offenses (if any);
- other known information of interest for the proceedings on the merits; applicant’s signature;
- date of the notification.

9.7. The employer reviews the notice and sends it to the structural unit or to the official responsible for combating corruption in the organization for registration of notices of appeals to incline employees to commit corruption offenses (hereinafter - the journal) (annex to these Provision) the day you receive the notice. <br>Anonymous notifications are transmitted to the structural unit or to the official responsible for combating corruption in the organization, for information. Anonymous notifications are registered, but not accepted for consideration.

9.8. Verification of the information contained in the notification is made within 15 business days from the date of registration of the notification.

9.9. In order to organize the inspection, the employer within three working days creates a commission to check the fact of the appeal to induce the employee of the organization to commit corruption offenses ((hereinafter - the commission).

9.10. The personal composition of the commission (chairman, deputy chairman, members and secretary of the commission) is appointed by the employer and is approved by the legal act of the organization.

9.11. During the inspection the following should be determined:
- the reasons and conditions that contributed to the person's appeal to an employee of the organization with the aim of inciting him to commit corruption offenses,
- the actions (inaction) of the employee of the organization, to the illegal execution of which the third party tried to incite him.

9.12. The results of the inspection are submitted to the employer in the form of a written conclusion within three days from the day the inspection ends.
The conclusion shall indicate:
- the composition of the commission;
- the inspection time;
- the applicant and the circumstances that gave rise to the inspection;
- the confirmation of the validity (or invalidity) of the fact that gave rise to the preparation of the notification;
- the reasons and circumstances that gave rise to the appeal in order to induce the employee of the organization to commit corruption offenses.

9.13. In the case of confirmation of the fact of appeal in order to induce the employee of the organization to commit corruption offenses, the commission in the conclusion makes recommendations to the employer on the implementation of measures to prevent corruption offenses. The employer makes a decision on the transfer of information to the prosecution authorities.

9.14. If the fact of appealing to induce an employee of the organization to commit corruption offenses was not confirmed, but during the inspection, there were signs of violations of requirements for corporate behavior or conflict of interest, the materials collected during the inspection, as well as the conclusion are sent for consideration at a public meeting (supervisory, board of trustees) council (if any) and the adoption of an appropriate decision, and also presented to the employer within two business days after completion of the inspection to decide on the application of the disciplinary Penalty.

10. Interaction with intermediaries and other persons, verification of contractors

110.1. DESKTOP LTD selects counterparties for rendering services based on the following principles:
- equality, fairness, non-discrimination and unreasonable restrictions on competition in relation to counterparties;
- honest and reasonable choice of the most preferred offers;
- targeted and cost-effective spending of money on the purchase of goods and services (including, if necessary, the cost of the life cycle of the purchased products) and the implementation of measures aimed at reducing the costs of the organization;
- prevention of corruption, conflict of interests and other abuses of authority.

10.2. DESKTOP LTD aims to have business relationships with counterparties that comply with the requirements of anti-corruption legislation and / or counterparties that declare the rejection of corruption.

10.3. DESKTOP LTD declares that it refuses to stimulate employees of counterparties in any way, including by providing monetary sums, gifts, donating works (services) to them and other ways not mentioned here, making the counterparty employee conditioned and aimed at ensuring that this employee performs any actions the organization will benefit from.

11. Information sharing and traning

11.1. DESKTOP LTD posts this Policy freely available on the official website on the Internet, openly declares opposition to corruption, welcomes and encourages compliance with the principles and requirements of this Provision by all contractors, its employees and other persons

11.2. DESKTOP LTD contributes to raising the level of anti-corruption culture by informing and systematically training employees in order to maintain their awareness of the company's anti-corruption policies and 
mastering the ways and techniques of applying anti-corruption policies in practice.

12. Anti-corruption measures

12.1. Anti-corruption measures include:
- development and adoption of a code of ethics and corporate behavior of employees;
- appointment of units or officials responsible for the prevention of corruption and other offenses;
- conducting anti-corruption expertise on concluded contracts,
- informing employees of the employer about cases of inclining them to commit corruption offences;
- informing the employer about information that has become known to the employee, about cases of corruption offenses committed by other employees, counterparties of the organization or other persons;
- informing the employer about the occurrence of a conflict of interest;
- conducting training activities on preventing and combating corruption;
- cooperation of the organization with law enforcement agencies
.

13. Cooperation with law enforcement agencies in corruption control

13.1. Cooperation with law enforcement agencies is an important indicator of the actual adherence of DESKTOP LTD to the declared anti-corruption standards of behavior. This cooperation can be carried out in various forms:
- need to report to the relevant law enforcement agencies about corruption offenses that have become known in the organization;
- assistance to authorized representatives of control and supervisory and law enforcement agencies in conducting inspections of the organization’s activities aimed at preventing and combating corruption;
- assistance to authorized representatives of law enforcement agencies in carrying out activities aimed at disrupting or investigation corruption crimes, including operational-searching measures;
- management and employees of the organization should not allow interference in the performance of official duties by judicial or law enforcement officials.

14. Measires of prevention and settlement ofconflict of interests

14.1. The management of conflict of interest in the DESKTOP LTD is based on the following principles:
- Mandatory disclosure of information about a real or potential conflict of interest;
- individual consideration and assessment of reputational risks for the organization while identification of each conflict of interest and its settlement;
- confidentiality of the disclosure of information on conflicts of interest and the process of its settlement;
- observance of the balance of interests between the organization and the employee in settlement of conflicts of interest;
- protection of the employee from prosecution connected to the information about the conflict of interest, which was promptly disclosed by the employee and settled (prevented) by the enterprise.

14.2. The present Provision fixes the following duties of employees connected to the disclosure and settlement of conflicts of interest:
- an employee of DESKTOP LTD is to take measures to prevent any possibility of a conflict of interest;
- to be guided by the interests of the organization without taking into account their personal interests, the interests of their relatives and friends when making decisions on business issues and performing job duties;
- to avoid situations and circumstances that could lead to a conflict of interest;
- to disclose a real or potential conflict of interest;
-to assist to the settlement of a conflict of interest.

14.3. The following types of disclosure of conflicts of interest is used in DESKTOP LTD:
- disclosure of information about a conflict of interest when applying for a job,
- disclosure of information about a conflict of interest when transferring to a new position;
- disclosure of information after occurrence of conflict of interest, etc.

14.4. An employee of the Organization is to notify in written form his direct manager about the conflict of interest that has occurred or about the possibility of its occurrence as soon as he becomes aware of this. The review of information submitted and the settlement of conflicts of interest should be confidential. The received information should be thoroughly checked by an authorized official to assess the seriousness of the organizational risks involved and the selection of the most appropriate form of the settlement of conflict of interest.

14.5. DESKTOP LTD can come to the conclusion that the situation, the information about which was provided by the employee, is not a conflict of interests and, as a result, does not need special ways of settlement.

14.6. DESKTOP LTD can also come to the conclusion that there is a conflict of interests and different ways to resolve it were used, including:
- restriction of employee access to specific information;
- voluntary refusal of the employee of the organization or his removal (permanent or temporary) from participation in the discussion and decision-making process on issues that are or may be affected by a conflict of interest;
- revision and change of functional duties of the employee;
- the temporary dismissal of an employee from professional duties, if his personal interests conflict with functional duties;
- transfer of an employee to a position which implies the performance of functional duties that do not related to a conflict of interest;
- transfer by the employee of his property to trust management, on which the conflict of interest can be based on;
- refusal of the employee from his personal interest, generating a conflict with the interests of the organization;
- dismissal of the employee from the organization on the initiative of the employee;
- dismissal of an employee on the initiative of the employer for the disciplinary offense, that is, for non-fulfillment or improper performance of his labor duties assigned to him due to his fault. <br>The above list of methods of settlement of conflicts of interest is not exhaustive. In each specific case, by agreement between DESKTOP LTD and the employee who discloses information about a conflict of interest, other forms of its settlement can be used.

14.7. The structural unit or official of the organization responsible for combating corruption is responsible for receiving information about a conflict of interest arising (existing).

14.8. Consideration of the received information is carried out collectively. Both the above-mentioned persons and other employees of the organization can take part in the consideration. The collegium shall issue written recommendations to the interested parties to resolve the conflict of interest not later than seven working days.

14.9. If a member of the collegium and an interested person is the same person, such member (members) of the collegium does not participate in the discussion of a conflict of interest and voting. In the case where a conflict of interest concerns the head of the organization, he also does not participate in decision making on this issue.

14.10. Information about the possibility of or the occurrence of a conflict of interest is presented in the form of a declaration of conflict of interest (annex to this Provision) in the following cases:
- when applying for a job, when being appointed to a new position, during the annual certification for compliance with the ethical standards of doing business adopted in the organization in the event of a conflict of interest.

14.11. This Provision is not aimed at describing all possible conflicts of interest that may arise. It should be used in any situation where the personal interest of the interested person contradicts the interests of DESCTOP LTD.

15. Responsibility for nonfulfillment (improper fulfillment) of this Provision

15.1. The head and employees of all divisions of Desktop LTD, regardless of their position, are responsible in accordance with the current legislation of the Russian Federation, for observing the principles and requirements of this Provision, as well as for the actions (inaction) of their subordinates who violate these principles and requirements.

15.2. Persons guilty of violating the requirements of this Provision may be brought to disciplinary, administrative, civil or criminal liability. This can be done on the initiative of Desktop LTD, law enforcement agencies or other persons in the manner and on the grounds provided for by the legislation of the Russian Federation, local regulations and labor contracts.

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