ISO certificates

01.11.2022., v.3.

1. The approved anti-bribery Policy (Policy) at “NewFuels” RSEZ SIA (Company) has been developed in accordance with the requirements of international standard ISO 37001 and national regulatory enactments, is based on an analysis of the current situation and sets a strategic goal and sub-goals for anti-corruption activities, compliance with regulatory requirements and obligations to satisfy anti-bribery management system requirements. Anti-corruption policy prohibits bribery and requires compliance with anti-bribery laws that are applicable to at “NewFuels” RSEZ SIA. Our anti-corruption policy provides a framework for setting, reviewing and achieving anti-bribery objectives and it’s appropriate to the purpose of the organization.

2. Purpose and Goals of Policy: anti- bribery Policy of “NewFuels” RSEZ SIA is intended to outline the Company’s risks related to bribery and corruption, to highlight responsibilities under both the relevant anti-corruption laws and Company ABMS manual and to provide with the tools and support necessary to identify and combat those anti-corruption risks. We encourage raising concerns in good faith, or on the basis of a reasonable belief in confidence, without fear of reprisal.

To achieve this goal, sub-goals have been identified:

2.1. To ensure useful and lawful handling of the company’s property, information, business management and strategy objectives, business and market partners, parties involved and interested in the activities of the company;

2.2. To ensure the “transparency” of raw materials, production fixed assets, public procurements;

2.3. To implement an open and effective personnel selection and management policy;

2.4. To reduce the possibility of conflict of interest of company officials;

2.5. To ensure appropriate and open environmental management and communication with the local government, the quality of provided services;

2.6. To improve the anti-bribery management system, its monitoring and control continually;

2.7. To explain the authority and independence of the anti-bribery compliance function

2.8. To explain the authority and independence of the anti-bribery compliance function

3. Scope and Range of application: “NewFuels” RSEZ SIA expects all directors, officers, employees, family members, consultants and third parties working on its behalf to refrain from engaging in any form of bribery or corruption, irrespective of citizenship, domicile, or location.  In addition to this general prohibition on bribery and corruption, this Policy and the ABMS manual and Procedure set forth several policy and procedural requirements that apply to all employees of “NewFuels” RSEZ SIA.

4. Risk assessment, due-diligence and/or consequences of non-compliance: A violation of relevant anti-corruption laws can lead to severe civil and criminal penalties and reputational harm to our Company.  Company employees that violate these laws can also face severe civil and criminal penalties, including jail time.  The prohibition against bribery is incorporated into our ABMS; thus, a violation of this Policy could also result in disciplinary actions pursuant to our ABMS including, but not limited to, termination of employment.

4.1. Risk assessments will be conducted on an annual basis to determine the level of controls necessary for a particular aspect of the Company’s operations, including in relation to procurement and tender processes.

Risk assessments should give consideration to:

(a) “country risk”, which includes an assessment of the overall risks of corruption and bribery associated with a particular jurisdiction;

(b) “transactional risks”, which includes an assessment of the risks associated with a business transaction undertaken by the Company or its Associated Entities;

(c) “business opportunity risks”, which includes the risk that pursuing or obtaining business opportunities may result in acts of bribery or corruption; and

(d) “business partnership risks”, which includes risks deriving from relationships with or partnership with other Associated Entities.

Specific procedure will be adapted and implemented to proportionately address the risks identified above as they arise.

Records and documentation must be kept of each risk assessment as part of the system of internal controls and record keeping.

4.2. Due diligence. The Company will conduct appropriate due diligence to inform risk assessments and ensure compliance with the Policy.

While the list is not exhaustive, and warning signs will vary by the nature of the transaction, expense/payment request, geographical market or business line, common warning signs that should be considered as part of any due diligence.

Records and documentation must be kept of due diligence as part of the system of internal controls and record keeping discussed ABMS manual.

5. Policy details:

5.1. Applicable Laws – Employees of the Company must abide by all applicable Anti-Bribery laws.  These laws generally prohibit both bribery of government officials and private sector (commercial) bribery. 

5.2. Prohibition of Bribery

5.2.1. Government Bribery – The Company and its employees are prohibited from giving, promising, offering, or authorizing payment of anything of value to any government official to obtain or retain business, to secure some other improper advantage, or to improperly influence a government official’s actions.  Additionally, Company associates must also avoid the appearance of improper interactions with government officials. 

5.2.2. Commercial Bribery – In addition to the prohibitions of bribing government officials discussed above, the Company prohibits employees from offering or providing corrupt payments and other advantages to or accepting the same from private (non-government) persons and entities.  Such payments constitute commercial bribery and are often called “kickbacks.” 

5.2.3. Facilitation Payments – The Company’s prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power or water service, or loading or unloading of cargo.  Generally, facilitation payments are prohibited by this Policy, except for a very limited set of circumstances for which prior written approval must be obtained from Member of the board of the Company.

5.3. Providing items of value to Government Officials

5.3.1. It’s forbidden to provide an item of value to any government official or entity

5.3.2. Gifts, Meals, Travel and Entertainment (“GMTE”) – It is never permissible to provide gifts, meals, travel, or entertainment to anyone (government officials or commercial partners) in exchange for any improper favour or benefit.  In addition, gifts of cash or cash equivalents, such as gift cards, are never permissible. 

5.3.3. Donations – It is never permissible to provide a donation to improperly influence a government official, or in exchange for any improper favour or benefit. 

5.3.4. Promoting, Demonstrating, or Explaining Products – It is never permissible to direct promotional expenses or activities to a government official to improperly influence him or her, or in exchange for any improper favour or benefit. 

5.3.5. Hiring or Engaging Government Officials – It is never permissible to hire or engage a government official, or his or her immediate family members, to improperly influence the official, or in exchange for any improper favour or benefit.  Note that before hiring a government official (or relative thereof) Company associates must first receive legal approval by Chairman of the board.

5.3.6. Political Contributions – It is never permissible to provide a political contribution to improperly influence a government official, or in exchange for any improper favour or benefit.   

5.4. Training – The Company requires that the following associates complete Anti-Bribery training every year:

All managers;

All employees with work experience more than 2 years;

The required Anti-Bribery training may include in-person or online training, a web-based Anti-Bribery training course, or instructor-led training programs. 

5.5. Auditing – Company employees will conduct periodic internal audits of relevant Company operations to help ensure the Company’s continued compliance with applicable Anti-Bribery laws this Policy and Company ABMS manual and Procedure.  It is the duty of all employees to cooperate with—and never interfere with or obstruct —such audit activities or Company investigations.  Company auditors are expected to act independently, and to liaise with Company Management to clarify any questions related to application of this Policy and Company ABMS manual and Procedure.

5.6. Record-keeping Company will be required to develop, implement, monitor and maintain a system of internal controls to facilitate compliance with this Policy, Company ABMS manual and Procedure, as well as to foster a culture of integrity and maintain high ethical standards throughout the Company. Book-keepers must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

5.7. Reporting Violations – Should you become aware of any situations that may violate the Company’s anti-bribery Policy, please contact the Anti-bribery Compliance Officer immediately – [email protected]. Suspected violations will be reviewed and investigated as appropriate and may lead to disciplinary action.  Any such reporting will be treated as confidential to the extent permitted by law.  The Company strictly prohibits retaliation for good faith reports of suspected misconduct.  Failure to report a violation of this Policy constitutes an independent violation of this Policy that is subject to discipline, up to and including termination of employment.