Anti-Corruption Policy

CHAPTER 1. GENERAL PROVISIONS

This Anti-Corruption Policy of HPBS Limited Liability Company (the “Company”) has been developed in accordance with the legislative acts of the Republic of Uzbekistan in the field of combating corruption, taking into account international standards and corporate governance best practices.

The provisions of this Policy comply with the principles of openness and transparency in conducting business and the inadmissibility of corrupt practices and are also intended to foster a high level of legal awareness and conscientious conduct among the Company’s employees.

This Policy is the Company’s principal internal regulatory document defining the key principles, objectives, and measures for preventing, detecting, and suppressing corruption offenses in the Company’s activities.

This Policy applies to all Company employees, regardless of their position, including management, as well as persons acting on behalf and/or in the interests of the Company under civil-law contracts.

The Company adheres to a principle of zero tolerance for corruption in all its forms and conducts its activities in strict compliance with the laws of the Republic of Uzbekistan.

The person or structural unit appointed by order of the Company’s Director and performing internal control and compliance functions is responsible for organizing and coordinating the Company’s anti-corruption work.

To implement its anti-corruption policy, the Company introduces a system of measures aimed at identifying, assessing, and minimizing corruption risks and establishing effective internal control mechanisms.

The Company engages in charitable and sponsorship activities exclusively on a voluntary and transparent basis, and such activities may not be used to obtain unlawful advantages or exert improper influence on decision-making.

Key terms and definitions

The following key terms are used in this Policy:

Corruption means abuse of official position, giving a bribe, receiving a bribe, or any other unlawful use of official position for personal gain.

Conflict of interest means a situation in which a Company employee’s personal interest affects or may affect the objective performance of the employee’s official duties.

Company Employee means an individual who has an employment relationship with the Company.

Officer means a person performing organizational and executive or administrative and business functions within the Company.

Responsible Person (Unit) means a person or structural unit appointed by order of the Company’s Director and performing functions relating to the implementation of the anti-corruption policy.

Bribe means the receipt or transfer of money, property, services, or other benefits of a proprietary nature in exchange for an act or omission in the interests of the giver.

Anti-corruption review means an analysis of the Company’s internal documents for the purpose of identifying corruption-conducive factors.

Charitable (Sponsorship) Activities means the Company’s voluntary provision of assistance free of charge.

CHAPTER 2. PRINCIPAL OBJECTIVES, TASKS, AND PRINCIPLES

The principal objective of the Company’s Anti-Corruption Policy is to establish and implement within the Company a system of measures aimed at preventing, detecting, and suppressing corruption offenses and ensuring compliance with the requirements of the laws of the Republic of Uzbekistan in the field of combating corruption.

The principal tasks of the Company’s anti-corruption policy include:

• fostering zero tolerance among Company employees for all forms of corruption;
• creating and implementing effective mechanisms for preventing corruption risks;
• ensuring transparency and openness in the Company’s activities;
• fostering a corporate culture based on the principles of honesty, integrity, and responsibility;
• minimizing the risk of the Company, its employees, and its counterparties becoming involved in corrupt activities;
• increasing the level of trust among partners, clients, and government authorities;
• ensuring compliance with business ethics and standards of conduct;
• timely detection and management of conflicts of interest;
• ensuring the operation of the internal control and corruption risk management system.

The Company’s Anti-Corruption Policy is based on the following principles:

Principle of legality — the Company and its employees strictly comply with the requirements of the laws of the Republic of Uzbekistan.

Principle of zero tolerance for corruption — the Company does not tolerate any form of corruption, regardless of its scale or circumstances.

Principle of transparency and openness — the Company’s activities are conducted on the basis of transparent decision-making and access to information within the limits established by law.

Principle of personal responsibility — each Company employee bears personal responsibility for compliance with the anti-corruption policy.

Principle of inadmissibility of conflicts of interest — the Company takes measures to identify and manage situations involving conflicts of interest.

Principle of inevitability of liability — persons who violate anti-corruption laws or this Policy are subject to liability in accordance with the established procedure.

Principle of internal control — the Company introduces and maintains internal control mechanisms aimed at preventing corruption offenses.

Principle of a comprehensive approach — anti-corruption measures are implemented systematically and cover all areas of the Company’s activities.

The Company ensures that all employees are informed of this Policy and takes measures to train employees and raise their awareness of anti-corruption matters.

CHAPTER 3. SCOPE OF THE ANTI-CORRUPTION POLICY AND OBLIGATIONS

This Anti-Corruption Policy applies to all Company employees, regardless of their position, length of service, or the nature of the functions they perform, as well as persons acting on behalf and/or in the interests of the Company under civil-law contracts.

The Company’s management, the heads of its structural units, and all Company employees are required to comply with this Policy.

The Company’s management plays a key role in fostering an anti-corruption culture and must set a personal example of adherence to the principles of integrity, honesty, and legality.

The obligations of the Company’s management include:

• ensuring the implementation and effective operation of the anti-corruption policy;
• organizing an internal control system aimed at preventing corruption offenses;
• creating conditions for the timely detection and management of conflicts of interest;
• taking measures to prevent corruption risks in the Company’s activities;
• ensuring that all employees are informed of the requirements of this Policy;
• reviewing reports of possible corruption and taking appropriate responsive measures.

The heads of the Company’s structural units must:

• ensure that employees of their units comply with this Policy;
• supervise the activities of subordinate employees;
• immediately inform the Company’s management of identified violations;
• take measures to prevent and manage conflicts of interest.

Company employees must:

• comply with the anti-corruption laws of the Republic of Uzbekistan and this Policy;
• refrain from actions that may be regarded as corruption offenses;
• immediately notify management or the Responsible Person of any known instances of corruption or attempts to involve them in corrupt activities;
• take measures to prevent conflicts of interest and report any such conflict in a timely manner;
• cooperate with internal reviews and investigations.

Company employees are prohibited from:

• accepting or giving bribes or acting as an intermediary in bribery;
• using their official position for personal purposes;
• participating in actions aimed at circumventing legal requirements;
• concealing instances of corruption offenses;
• taking any other actions that violate this Policy.

The Company expects its counterparties, partners, and other third parties to comply with the principles of anti-corruption conduct and may include corresponding terms in contracts.

Compliance with this Policy is monitored by the Company’s management and the appointed Responsible Person (Unit).

CHAPTER 4. PREVENTION AND MANAGEMENT OF CONFLICTS OF INTEREST

For the purpose of preventing corruption offenses, the Company pays particular attention to the identification, prevention, and management of conflicts of interest.

A conflict of interest arises in a situation where a Company employee’s personal interest, whether direct or indirect, affects or may affect the proper performance of the employee’s official duties and results or may result in a conflict between the employee’s personal interests and the Company’s interests.

Personal interest may take the form of income, benefits, or advantages received by the employee, the employee’s relatives, or other persons connected with the employee.

To prevent conflicts of interest, Company employees must:

• avoid situations in which a conflict of interest arises or may arise;
• notify the Company’s management or the Responsible Person in a timely manner, in writing or another established form, of the occurrence or possible occurrence of a conflict of interest;
• refrain from participating in decisions on matters in which the employee has a personal interest;
• comply with the requirements of the Company’s internal regulatory documents.

The Company’s management must:

• provide conditions for identifying conflicts of interest;
• review employee notices of conflicts of interest;
• take measures to manage a conflict, including, where necessary, recusing the employee from decision-making, redistributing official duties, or taking other measures;
• monitor employees’ compliance with requirements relating to the prevention of conflicts of interest.

The Company may apply the following measures to manage a conflict of interest:

• changing the employee’s official duties;
• temporarily or permanently recusing the employee from decision-making;
• transferring the employee to another position;
• other measures aimed at eliminating the causes of the conflict of interest.

An employee’s failure to provide information about a conflict of interest, as well as concealment of such information, is regarded as a violation of this Policy and may result in liability measures.

The Company maintains the confidentiality of information received in connection with the management of a conflict of interest, except in cases provided for by law.

CHAPTER 5. GIFTS, BUSINESS HOSPITALITY, AND OTHER BENEFITS

To prevent corruption offenses, the Company establishes restrictions on giving and receiving gifts and on providing and receiving business hospitality.

Gifts, business hospitality, and other benefits may be given or received only within generally accepted business practices, must be reasonable and lawful, must not contravene the laws of the Republic of Uzbekistan, and must not influence decisions made by Company employees.

Company employees are prohibited from:

• receiving gifts, money, services, or other benefits from individuals or legal entities where such actions may affect the objectivity with which they perform their official duties;
• providing gifts, money, services, or other benefits for the purpose of obtaining advantages in the Company’s activities;
• accepting monetary gifts, regardless of the amount;
• concealing the receipt or transfer of gifts and other benefits;
• taking actions that may be regarded as an attempt to exert improper influence.

Gifts and business hospitality may be given and received provided that all of the following conditions are met:

• the gift or business hospitality complies with generally accepted standards of business ethics;
• it is not provided on a regular basis;
• it is not connected with making decisions in the donor’s interests;
• it is of reasonable value;
• it does not create reputational risks for the Company.

If an employee receives a gift that does not comply with this Policy, the employee must notify the Company’s management or the Responsible Person and take steps to refuse or return the gift.

All instances of giving and receiving gifts and business hospitality may be recorded in accordance with the procedure established by the Company.

Business hospitality expenses must be reasonable, documented, and consistent with the purposes of the Company’s activities.

The Company does not permit gifts and business hospitality to be used as a means of concealing corruption offenses.

Compliance with this Chapter is monitored by the Company’s management and the Responsible Person (Unit).

CHAPTER 6. INTERACTION WITH GOVERNMENT AUTHORITIES AND COUNTERPARTIES

The Company interacts with government authorities, their officials, and other organizations strictly within the framework of the applicable laws of the Republic of Uzbekistan and on the basis of the principles of legality, transparency, and integrity.

Company employees are prohibited from:

• offering, promising, giving, demanding, or receiving bribes or other improper benefits in interactions with government authorities and their officials;
• making unofficial payments, including so-called “facilitation payments,” for the purpose of obtaining advantages;
• using intermediaries, agents, or other third parties to perform actions that contravene anti-corruption laws;
• misleading representatives of government authorities or providing inaccurate or distorted information.

All interactions with government authorities must be conducted exclusively by authorized Company employees within the scope of the authority granted to them.

The Company ensures accurate records of all transactions related to interaction with government authorities and retains the relevant documents in accordance with the established procedure.

When selecting counterparties, the Company follows the principles of integrity, transparency, and economic justification.

To minimize corruption risks, the Company conducts due diligence on counterparties, including:

• analysis of business reputation;
• checks for information indicating involvement in corruption offenses;
• assessment of financial stability and trustworthiness.

The Company may include anti-corruption clauses in agreements with counterparties requiring the parties to comply with anti-corruption laws and this Policy.

If a counterparty is found to have violated anti-corruption requirements, the Company may take measures, including refusing further cooperation and terminating the contractual relationship in accordance with the established procedure.

Company employees must exercise due care when interacting with counterparties and immediately inform management of identified risks or violations.

Compliance with this Chapter is monitored by the Company’s management and the Responsible Person (Unit).

CHAPTER 7. INTERNAL CONTROL, REPORTING OF VIOLATIONS, AND INVESTIGATIONS

To ensure compliance with anti-corruption laws and this Policy, the Company introduces an internal control system aimed at preventing, detecting, and suppressing corruption offenses.

The internal control system includes:

• identification and assessment of corruption risks in the Company’s activities;
• development and implementation of measures to minimize them;
• regular reviews and monitoring of compliance with this Policy;
• analysis of the effectiveness of measures taken and their improvement.

Company employees must immediately report any instances of corruption offenses that become known to them, as well as attempts to involve them in corrupt activities.

Reports may be submitted to:

• the immediate supervisor;
• the Company’s Director;
• the Responsible Person (Unit) performing internal control functions.

The Company provides the ability to submit reports on a confidential basis, among other methods.

Persons who report possible violations in good faith are protected from all forms of retaliation, including dismissal, demotion, discrimination, or other adverse consequences.

All reports of violations are subject to mandatory review within a reasonable period.

Following the initial review, a review or internal investigation is conducted, during which:

• information is collected and analyzed;
• explanations are requested from employees and other persons where necessary;
• measures are taken to establish the facts.

Based on the results of the investigation, a decision is made as to whether a violation occurred and whether responsive measures are required.

If a violation is confirmed, the Company takes measures aimed at:

• remedying the identified violations and their consequences;
• holding the responsible persons liable;
• preventing similar violations in the future.

Information on the results of the review may be communicated to interested parties subject to confidentiality and legal requirements.

The operation of the internal control system and the review of reports of violations are monitored by the Company’s management and the Responsible Person (Unit).

CHAPTER 8. LIABILITY AND FINAL PROVISIONS

Company employees are liable for failure to comply with the requirements of the laws of the Republic of Uzbekistan in the field of combating corruption and this Anti-Corruption Policy in accordance with the laws of the Republic of Uzbekistan, the Company’s internal documents, and the terms of their employment contracts.

Persons guilty of corruption offenses may be subject to disciplinary, financial, administrative, or criminal liability in accordance with the procedure established by the laws of the Republic of Uzbekistan.

Disciplinary measures may include:

• an admonition;
• a reprimand;
• deprivation of a bonus or other incentive payments;
• termination of the employment contract;
• other measures provided for by the Company’s internal documents and the law.

If the Company incurs damage as a result of corruption offenses, the persons at fault must compensate for the damage in accordance with the established procedure.

The Company may submit materials concerning identified violations to authorized government bodies in accordance with the laws of the Republic of Uzbekistan.

Responsibility for monitoring compliance with this Policy rests with the Company’s Director and the Responsible Person (Unit) performing internal control functions.

This Policy must be communicated to all Company employees against signature or by another method that confirms acknowledgment.

The Company provides regular anti-corruption training to employees and raises their awareness of the requirements of the law and this Policy.

This Policy enters into force upon its approval and remains effective until a new revision is adopted.

Amendments and additions to this Policy are made on the basis of a decision of the Company’s Participant or Director in accordance with the established procedure.