Ethics and Combating Corruption

An important part of the ESG aspects is the high quality of corporate governance (G — Governance), which implies, among other things, the implementation of best practices in the activities of INK Group in the field of compliance with ethical norms and combating corruption.

The INK Group has regulations that form an important part of the corporate governance system and are aimed at increasing transparency of operations, compliance with ethical standards, and combating corruption:

The current Policy (approved by the Board of Directors of JSC INK-Capital on October 25, 2021) was developed together with a leading international legal counsel who is in the first tier of the Legal 500 and one of top five law firms in the USA according to the Vault Law 100; the Policy takes into account the laws of the United States, Great Britain and France, as well as the best world practices on combating the legalization (laundering) of proceeds received from crime. The requirements of the above documents are binding on all employees of the Group and members of the management and control bodies of each Group company.

Since 2014, the INK Group has operated an anonymous whistleblowing hotline, where you can use any convenient way to report violations and various abuses by individual Group officials. Allegations received through the trust lines are reviewed by the Ethics Commission. In 2021, the INK Group's Whistleblowing hotline ranked among the best in Russia. The relevant results of a study of the 100 largest Russian companies by revenue were presented by experts of an independent international human rights organization.

The Board of Directors of JSC INK-Capital has been approving and monitoring the implementation of the compliance system development program for the respective year for several years, as well as considering issues in relation to corruption risks.