Approved by
Director Mr. Igor Burkynskyy
on 01/10/2018
(in accordance with recommendations of a practical anti-corruption guide for businesses in Singapore of the Corrupt Practices Investigation Bureau of Singapore)
1. ANTI-CORRUPTION POLICY
YUG-NEFTEGAZ PRIVATE LIMITED (hereinafter – YNG) and its subsidiaries and affiliates worldwide are committed to conducting our business with honesty, integrity, trustworthiness, and accountability. We have a responsibility to comply with the Prevention of Corruption Act dd. 17 June 1960 and all applicable laws in the countries where we do business.
Our policy is straightforward: all employees, representatives, directors (YNG or any of its subsidiaries or affiliates) may not pay bribes or otherwise try to improperly influence anyone – in the government or in the private sector – even if such a payment is requested. This is true whether an improper payment is made directly through a YNG employee or through a third party, such as an agent or representative, vendor, client, partner, or other service provider.
This policy applies to all YNG employees, wherever located. All employees are responsible for compliance with this policy in their conduct on behalf of the Company. YNG management is responsible for ensuring that employees under their supervision and authority comply with this policy. Management has vested certain employees with compliance responsibilities. Compliance personnel will assist YNG employees in understanding and complying with this policy, and will take steps to maintain and implement an anti-corruption program, but the responsibility for compliance shall remain with YNG employees. YNG operations in specific countries may issue additional specific anti-corruption guidelines to conform to local laws or to address local circumstances. Any additional, country-specific guidelines must be consistent with this policy. No violation of federal, state, or foreign laws will be permitted or tolerated.
2. OUR APPROACH
- Our Company is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Our Company will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.
- Our Company adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Our Company and employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices.
- Our Company does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, from any organisation, firm or individual with whom they deal with in the course of the employment.
- Our Company does not allow our employees to promise or offer to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment.
- Our Company has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.
- Our Company has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.
- If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.
- Our Company will also strive to ensure that our business partners share our zerotolerance policy against corruption and bribery. Our Company will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
3. POLICY VIOLATION
Any YNG employees who become aware, or suspect, that this Policy may have been violated shall immediately notify the Director or the officer of YNG.
The identity of any person reporting a suspected violation or violation will remain confidential, except to the extent necessary for the protection of YNG interests or as required by applicable law.
YNG will not tolerate retaliation against anyone who makes a report in good faith, as stated in this Policy. Anyone who experiences what they believe to be any form of retaliation should report this concern as soon as possible to the Director or any officer of YNG.
Employees who violate this Policy are subject to disciplinary action, up to and including dismissal and also may be subject to individual criminal and/or civil prosecution in relevant jurisdictions. Business Partners who violate this Policy are subject to termination of all commercial relationships with YNG.