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Executive compliance policy

LANIT Group. Executive compliance policy. Terms and definitions. Our mission.

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Executive compliance policy

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  1. LANIT Group Executive compliance policy

  2. Terms and definitions

  3. Our mission LANIT Groups mission is to promote modern information technologies in Russia. Main goal is to enhance customers’ business efficiency by implementing high-tech IT-solutions. Together with our customers we program the future by facilitating the spread of achievements of scientific and technical progress in Russia. At the moment the group is comprised of companies each being a leader in its own segment of IT-market. Synergy of their combined effort allows undertaking largest and most complex projects. LANIT Groups clients are the biggest Russia’s enterprises and organizations: ministries and governmental agencies, banks and financial companies, oil and gas companies, power supply companies and others. In order to fulfill customers’ demands at the highest level LANIT Group constantly expands service and product range, increases technical expertise of employees on the edge of hi-end technologies.

  4. Compliance policies

  5. External policy Anti-corruption Anti-bribery Transparency Risk management

  6. Anti-corruption policies LANIT Group is concerned about the seriousness of problems and threats posed by corruption to the stability and security of societies, undermining the institutions and values of democracy, ethical values and justice and jeopardizing sustainable development and the rule of law. LANIT Group cooperate with local officials in order to interrupt or prevent any acts of bribery, fraud, money laundering and any other form of corruption. LANIT Group constantly develop it’s own anticorruption compliance policy and complywith any anticorruption laws, regulations and instructions.

  7. Anti-bribery policies LANIT Group compliance policy determines bribery as giving or receiving money, any offers gifts of something of value or advantage. It might also include meals, entertainment, travel. LANIT Group strongly prohibits giving or receiving any bribes by its employees. If any gift that is given to LANIT Group employee is may be reviewed as a bribe an employee should avoid taking or giving such gift.

  8. Transparency policies As a part of anticorruption policies LANIT Group obey local laws and comply with financial authorities and alsofollows Transparency International recommendations. LANIT Group was highly rated by Transparency International Russia in its annual Transparency rating and was awarded for its determination in anti-bribery policy. LANIT Group is proud to be among the top-3 companies in Russia having the most detailed compliance programs according to the Transparency International research. Insider information usage is prohibited by LANIT Group policies. Transparency International - https://transparency.org.ru/special/trac2018russia/en/, https://transparency.org.ru/special/trac2018russia/docs/report-en.pdf

  9. Internal compliance threats Harassment Bullying Discrimination

  10. Internal compliance LANIT Group is committed to providing a safe and respectful workplace free from all forms of discrimination, harassment and bullying. Discrimination, harassment and bullying is unlawful. LANIT Group has zero tolerance towards discrimination, harassment and bullying in the workplace. LANIT Group requires all managers and supervisors to ensure that all employees are treated fairly and equitably, which includes not being subjected to harassment, discrimination or bullying. LANIT Group strongly discourages romantic or sexual relationships between a manager or other supervisory employee and his or her staff (an employee who reports directly or indirectly to that person) because such relationships tend to create compromising conflicts of interest or the appearance of such conflicts. In addition, such a relationship may give rise to the perception by others that there is favoritism or bias in employment decisions affecting the staff employee. Discrimination in violation of this policy will be subject to disciplinary measures up to and including contract termination.

  11. Discrimination It is a violation of LANIT Group policy to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information or marital status. Discrimination of any kind is strictly prohibited by LANIT Group internal policy.

  12. Harassment and Bullying LANIT Group prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce an employee, co-worker, or any person working for or on behalf of LANIT Group. Harassment also includes sexual harassment as a form of unlawful employment discrimination. Sexual harassment in verbal, non-verbal or physical form is prohibited under LANIT Group anti-harassment policy. LANIT Group prohibits any form of bullying in the workplace. Every act of bullying will be subject to disciplinary measures up to and including contract termination.

  13. Internal control LANIT Group pays special attention to its internal control. LANIT Group analyzes its business partners and contractors to match its financial liabilities. Every contractor is checked both by Financial and Legal departments of LANIT Group. Major LANIT Group units are audited by one of the Big 4 on a regular basis.

  14. Risk management LANIT Group pays significant attention to Risk management. LANIT Group identify, analyze and minimize internal and external risks. Each kind of risks is included in a special risk register and allocated on a Map of risks LANIT Group analyze its business partners and contractors to match its financial liabilities. Every contractor is checked both by Financial and Legal departments of LANIT Group.

  15. Sources of compliance policy UN Conventions Laws of the current country UK Bribery Act 2010 Foreign Corrupt Practices Act 1977

  16. How we do it In 2017 LANIT Group empowered a special compliance committee to control and develop its own compliance policy. Compliance committee’s acts are obligatory to all LANIT Group employees, managers subsidiaries as well as main contractors. Once per year every employee is required to pass the training, sign and acknowledge the ‘code of conduct’ policy. In our policy we clearly state protection for employees on reporting the compliance concerns, provide special e-mail compliance@lanit.ruand hotline@lanit.ru for reporting of such cases. LANIT compliance program - https://www.lanit.ru/about/compliance-policy/

  17. How we do it • LANIT Group follows world’s most efficient compliance politics. We also apply our vendors partner’s programs: • HPE / HP Inc. • Cisco • Hitachi • Dell Technologies • APC. • We are proud to state that for now LANIT Group has fulfilled the implementation of compliance policy in its corporate procedures.

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