Anti-bribery policy
ECOGRAIN LLC (hereinafter — the "Company") adheres to a policy of zero tolerance to any form of corruption, bribery and abuse of position. This Policy establishes the basic principles and rules of conduct aimed at preventing corruption in all areas of the Company's activities.
1. General provisions and scope
This Policy applies to all employees of the Company, regardless of their position, as well as to contractors, partners and intermediaries acting on behalf of or in the interests of the Company. The Policy has been developed in accordance with the legislation of the Russian Federation and international anti-corruption standards.
2. Basic principles
The Company's activities are based on the following principles:
- Strict compliance with anti-corruption legislation of all countries of presence.
- Inadmissibility of any form of bribery and commercial bribery.
- Transparency and openness of business relations with contractors.
- Inadmissibility of conflict of interest and its timely resolution.
- Personal responsibility of each employee for compliance with anti-corruption standards.
3. Prohibited actions
Company employees are prohibited from: offering, promising or giving bribes to any persons, including public officials; receiving bribes or other illegal remuneration for performing actions (or inaction); using official position for personal gain; participating in or facilitating corruption schemes; accepting gifts or services that may affect the objectivity of decisions made, except for business gifts of symbolic value (not more than 3,000 rubles) and only within the framework of business etiquette.
4. Employee obligations
Each employee is obliged to: comply with this Policy and current legislation; immediately report to his/her supervisor or to the security service about any known facts of corruption; refrain from actions that may be perceived as corrupt; undergo training on anti-corruption topics; contribute to the formation of an anti-corruption culture in the team.
5. Liability for violation
Violation of the requirements of this Policy entails disciplinary, administrative and criminal liability in accordance with the legislation of the Russian Federation. Disciplinary sanctions up to dismissal are applied to employees. With regard to contractors, termination of contracts and application of other sanctions provided for by agreements are provided.
6. Procedure for reporting violations
About any cases of corruption or attempts to induce the commission of corrupt actions, it is necessary to immediately inform: your immediate supervisor; the Company's security department by phone +7 (909) 214-50-72; by email nachot@ecozerno36.ru. Anonymity is guaranteed, and the fact of the report will not entail negative consequences for a bona fide employee.
7. Final provisions
This Policy is binding on all employees of the Company. The Company reserves the right to make changes to the Policy due to changes in legislation or internal regulations. All changes are published on the official website of the Company. Employees and contractors are obliged to familiarise themselves with the current version of the Policy.
Last updated: August 21, 2026.