Code of Ethics

Code of Ethics

1. Definitions

1.1. Ethics are the rules and norms of behavior of individuals and employees of the TIMOSHA Limited Liability Company (next - TIMOSHA Company).

1.2. The Code of Ethics is a set of rules for Employees of the Company "TIMOSHA", formed in accordance with Law № 273-FL "On Countering Corruption".

1.3. Conflict of interest is a situation in which the personal interest of an employee of the Company "TIMOSHA" can be harmful for the interests of the Company "TIMOSHA".

1.4. Corruption – includes the following actions of an individual:

• abuse of official position;

• giving a bribe;

• receiving a bribe;

• abuse of authority;

• commercial bribery;

• other illegal usage of their official position contrary to the legitimate interests of the Company "TIMOSHA" and the state.

These actions are performed to obtain benefits in the form of money, valuables, other property or services of a proprietary nature, other property rights for themselves or for third parties, or the illegal provision of such benefits by other individuals.

1.5. A bribe is the receipt by an individual, including employees of the Company, personally or through an intermediary of any material values (money, securities, items of services and other property benefits) for an action or omission in the interests of the bribe–giver, which this individual could not or should not have committed due to his official position.

1.6. Prevention of corruption – the Company's activities aimed at introducing elements of corporate culture, organizational structure, rules and procedures regulated by internal regulatory documents, ensuring the prevention of corruption.

1.7. Insider information – official information of the Company "TIMOSHA", not publicly available.

1.8. Business reputation (image) is an intangible benefit, which is an assessment of the activities of the Company "TIMOSHA" in terms of their business qualities.

1.9. Risk – the impact of uncertainty on the goals of the Company "TIMOSHA" (GOST R ISO 31000:2010).

• Uncertainty – lack of information, understanding or knowledge about an event, its consequences or its possibility.

• The purpose of the Company "TIMOSHA" as a commercial organization is to make a profit (Article 50 of the Civil Code of the Russian Federation).

• The financial result is the economic result of the economic activity of the Company "TIMOSHA", expressed in monetary form (profit or loss).

• Reputational risk – the adverse impact of the image of the Company "TIMOSHA" on its customers, counterparties, shareholders (participants), business partners, regulatory authorities, on which the financial result of the Company "TIMOSHA" depends.

• Corruption risk – the adverse impact of corruption on the financial result of the Company "TIMOSHA".

• Property risk – adverse impact on the financial result of the Company "TIMOSHA" of the following actions: theft, damage, embezzlement of property, as well as negligent attitude to it, its use for illegal or unethical purposes.

• Risk factor – a circumstance affecting the occurrence of risk.

2. Purpose of the Code of Ethics

2.1. This Code of Ethics of the Company "TIMOSHA" is a document of the Company "TIMOSHA" defining:

• key norms, rules, requirements and principles aimed at the formation of uniform ethical standards of the Company "TIMOSHA" and its employees in relation to the key business processes of the Company "TIMOSHA", as well as in relations with government employees, business partners, shareholders, mass media;

• the duty of members of the Board of Directors and employees of the Company "TIMOSHA", regardless of their position, to know and comply with the principles and requirements of the Code of Ethics;

• the procedure for familiarizing TIMOSHA employees with the requirements of the Code of Ethics;

• procedures for monitoring compliance of TIMOSHA employees with the norms, rules, requirements and principles of the Code of Ethics;

• the procedure for informing the management of the Company "TIMOSHA" about the identified or probable non-compliance with the Code of Ethics;

• the responsibility of TIMOSHA employees for non-compliance with the Code of Ethics.

3. Scope of application

3.1. The Code of Ethics reflects the Company's "TIMOSHA" commitment to high ethical standards of conducting open and honest business, designed to ensure the improvement of corporate culture, adherence to the best practices of corporate governance and maintaining the business reputation of the Company "TIMOSHA".

3.2. All employees of the Company "TIMOSHA" must be guided by this Code of Ethics and strictly comply with its principles and requirements in daily work and during the implementation of any projects of the Company "TIMOSHA".

3.3. The Company's "TIMOSHA" documents, including those regulating relations with authorities, business partners, shareholders and employees of the Company "TIMOSHA", are developed and approved taking into account the principles and requirements of this Code of Ethics.

3.4. Certain provisions of the Code of Ethics and the procedure for their implementation may be disclosed in more detail in the internal documents of the Company "TIMOSHA", including local regulations, policies, codes, regulations, regulations, job descriptions, as well as employment contracts of employees of the Company "TIMOSHA".

3.5. The provisions of this Code of Ethics are recommended for implementation and compliance in all Companies of the Company "TIMOSHA" (hereinafter referred to as the Company "TIMOSHA").

3.6. The principles and requirements of the Code of Ethics apply to all aspects of the activities and business processes of the Company "TIMOSHA", including in the following areas:

• respect for the legitimate rights and interests of The Company's "TIMOSHA" shareholders and investors, timely and reliable disclosure of information;

• prevention of corruption;

• fair competition;

• interaction with public authorities and civil servants;

• compliance with the rules of working with insider information and the inadmissibility of insider transactions;

• identification and resolution of conflicts of interest;

• proportionality of representation expenses and business gifts;

• protection of confidential information;

• use of the property of the Company "TIMOSHA";

• mutual respect and mutual assistance of TIMOSHA Company employees.

4. Guiding ethical principles of TIMOSHA Company 

4.1. Trust: over the years of its existence, the Company "TIMOSHA" has managed to gain the trust of counterparties and customers by building friendly partnerships with its shareholders, investors and employees, which the Company "TIMOSHA" firmly intends to maintain, strengthen and develop in the future.

4.2. Openness: The Company's "TIMOSHA" transparent information policy not only guarantees the right of all interested parties to receive reliable and up-to-date information about the activities of the Company "TIMOSHA", but also is one of the most important components of our corporate culture.

4.3. Respect for people: the personnel policy of the Company "TIMOSHA" is expressed in providing equal opportunities to all employees regardless of their national and religious affiliation, political views, personal beliefs, gender and age.

4.4. Professionalism: the Company "TIMOSHA" makes all decisions on the basis of properly verified data and on the basis of professionally sound judgments.

4.5. Impartiality and objectivity: all decisions of the Company "TIMOSHA", including the selection of counterparties, partners, the formulation of terms of interaction with them, personnel and administrative decisions are carried out on transparent, fair market conditions without unreasonable preferences or prejudices, as well as on the basis of professionally sound judgments.

4.6. Rejection of corruption and unfair competition: the Company "TIMOSHA" refrains from participating in unethical, illegal or unfair activities, and also makes reasonable efforts and measures to ensure that business partners, contractors, contractors, employees of TIMOSHA adhere to the same high ethical standards in business relations.

5. Informing

5.1. The requirements of this Code of Ethics are brought to the attention of all employees of the Company "TIMOSHA" when applying for a job under the signature, and are publicly available on the official website of the Company "TIMOSHA" and the internal corporate portal of the Company "TIMOSHA" free review.

6. Relations of the companies of the Company "TIMOSHA", employees and contractors

6.1. The management of the Company "TIMOSHA" is responsible for the formation of ethical standards, and also provides conditions under which employees and contractors of the Company "TIMOSHA" have the opportunity to know and understand the basic principles of the Code of Ethics and see how these principles are implemented in practice in the behavior of employees of the Company "TIMOSHA".

6.2. The Company "TIMOSHA" builds relationships with employees on the basis of common goals, mutual respect, long-term partnership, consideration of mutual interests, integrity, impartiality and assumes the following obligations to the employees of the Company "TIMOSHA":

• comply with the labor legislation of the Russian Federation and the terms of employment contracts;

• respect human rights and individual freedom;

• maintain an atmosphere of friendliness, mutual understanding and stability;

• avoid any form of discrimination or harassment;

• ensure a decent level of pay and labor protection;

• create conditions for safe, comfortable and productive work;

• make objective personnel decisions based on the results of work;

• provide opportunities for professional and personal growth;

• take into account the opinion of employees and organize feedback channels;

• support initiatives to improve the efficiency of business processes;

• develop and improve training and motivation systems;

• respond to suggestions, ideas, demands and complaints;

• prevent unauthorized dissemination of personal data;

• respect the cultural traditions of the country.

6.3. All employees of the Company "TIMOSHA" are obliged to comply with the following ethical principles and norms:

• comply with the requirements of applicable legislation and internal documents of the Company "TIMOSHA";

• take care of the reputation of the Company "TIMOSHA" and be guided by its interests in professional activities;

• refrain from unfair methods of competition and business conduct;

• adhere to the principle of rejection of corruption in all forms and manifestations;

• demonstrate a personal example of ethical behavior;

• be honest and decent in business and personal relationships;

• treat colleagues and contractors of the Company "TIMOSHA" respectfully and politely, provide support to new employees;

• not infringe on the personal dignity of subordinates and colleagues;

• observe the standards of appearance ("dress code");

• observe subordination, be extremely correct, treat all colleagues and subordinates equally;

• to prevent unreasonable or unfair personnel decisions;

• to stop any actions that are questionable from a legal and ethical point of view;

• not to use for personal purposes the official position, confidential and insider information, tangible and intangible assets of the Company "TIMOSHA";

• not to mislead colleagues and business partners of the Company "TIMOSHA", not to provide false or unverified information;

• make decisions only after a comprehensive and thorough study of the situation;

• timely execute management orders, respond to requests from colleagues, contractors;

• take care of the continuous improvement of their professionalism and qualifications;

• perform their official duties in the most effective way;

• take into account the interests of all parties interested in business relations;

• share experience and information with colleagues and subordinates;

• refrain from actions or omissions that cause a conflict of interest;

• strive to find compromises and friendly settlement of disputes;

• inform the management about the property and reputational risks of the TIMOSHA Company;

• avoid decisions that entail unjustified reductions in employment at the Company "TIMOSHA";

• to prevent statements (including in social and Internet networks) that may cause reputational and property damage to the company;

• use your own working time and the time of your colleagues rationally.

6.4. In order to develop the corporate culture and promote compliance with the principles set forth in this Code of Ethics, the Management of the Company "TIMOSHA" must:

• be an example in compliance with applicable legislation and business ethics standards in the daily activities of the Company "TIMOSHA" and in decision-making;

• ensure that the Company’s "TIMOSHA"  employees understand and comply with the requirements of this Code of Ethics;

• report non-compliance or potential non-compliance with applicable legislation and ethical standards.

6.5. An employee of the Company "TIMOSHA" cannot be subjected to any penalties or harassment if he initiates or discusses ethics issues with his colleagues and supervisors, and must be confident in confidentiality guarantees.

7. Approach to the implementation of the ethical principles of the Company "TIMOSHA"

7.1. Respect for the legitimate rights and interests of all shareholders and investors of the Company "TIMOSHA", timely and reliable disclosure of information

7.1.1. When making decisions, the Management of the Company "TIMOSHA" should equally take into account the rights and strive to balance the interests of all shareholders and investors of the Company "TIMOSHA", relations with which are built on the basis of trust and mutual respect.

7.1.2. The key principles of interaction with shareholders and investors are compliance with high standards of corporate governance, information openness and reliability of the Company’s "TIMOSHA" reporting, which imply providing all shareholders and investors with equal opportunities, including protection of their rights and timely access to information.

7.1.3. In order to provide all shareholders, investors and other interested parties with free and equal access to information, the Company "TIMOSHA" organizes timely and reliable public disclosure of insider information in accordance with the requirements of applicable legislation and the rules of the securities market regulators of the Russian Federation and those countries on whose exchanges the Company "TIMOSHA"  securities are listed.

7.1.4. At the end of the reporting periods, the Company "TIMOSHA" publicly discloses data on financial results and risk factors, an analysis of indicators for previous periods, a description of key events, information on credit ratings and corporate governance ratings, a calendar of events important to the investment community and other significant facts, if necessary, issuing press releases and organizing conferences with with the participation of analysts and media representatives.

It is implemented in the Company "TIMOSHA"

7.1.5. Employees of the Company "TIMOSHA" when making management decisions and participating in the work of the management bodies of the Company "TIMOSHA" must comply with the norms and requirements of applicable legislation, as well as internal regulatory documents of the Company "TIMOSHA".

7.1.6. Employees of the Company "TIMOSHA", owners of business processes, are required to inform the Directorate of Legal Affairs about all known facts and events that are subject to disclosure.

7.1.7. Employees of the Company "TIMOSHA" who do not have authority to interact with the media and/or regulators are prohibited from making direct and indirect contacts with the media and/or the investment community on any issues related to the activities of the Company "TIMOSHA", including giving any comments, making any statements on behalf of persons of the Company "TIMOSHA" or on their own behalf as an employee of the Company "TIMOSHA" without prior approval from the Legal Department and the Marketing, Advertising and Public Relations Department.

7.1.12. When interacting with the media, the investment community and regulators, all employees of the Company "TIMOSHA"  and structural divisions are guided by internal regulatory documents of the Company "TIMOSHA" concerning work with information and its disclosure, including documents regulating the rules for handling information representing trade secrets and/or insider information.

7.2. Prevention of corruption

7.2.1. The Company "TIMOSHA"  strictly adheres to the principle of non-acceptance of corruption in any forms and manifestations, including in interaction with shareholders, investors, counterparties, representatives of authorities, self-government, political parties and other persons, when carrying out daily activities and implementing projects in any of the areas of activity of the Company "TIMOSHA".

7.2.2. The anti-corruption policy of the Company "TIMOSHA" based on the following basic principles:

• conducting periodic assessment of corruption risks;

• verification of the reliability of counterparties;

• implementation of monitoring and control.

• For non-compliance with the applicable anti-corruption legislation and/or the anti-corruption policy of the Company "TIMOSHA", any employee of the Company "TIMOSHA" may be subject to liability measures provided for by applicable law, this Code of Ethics and other internal documents of the Company "TIMOSHA".

It is implemented in the Company "TIMOSHA"    

7.2.3. In accordance with the internal anti-corruption policy of the Company "TIMOSHA" implemented by the Directorate for the Protection of Resources and other internal regulatory documents of the Company "TIMOSHA":

• The Company "TIMOSHA" does not finance charitable and sponsorship projects in order to obtain commercial advantages in specific projects;

• The Company "TIMOSHA" does not finance political parties, organizations and movements in order to obtain commercial advantages in specific projects of the Company "TIMOSHA";

• The Company "TIMOSHA" refrains from paying any expenses for government employees and their close relatives (or in their interests) in order to obtain commercial advantages in specific projects of the Company "TIMOSHA", including expenses for transportation, accommodation, meals, entertainment, PR campaigns or receiving them at the expense of the Company "TIMOSHA" has other benefits;

• The Company "TIMOSHA" makes reasonable efforts and takes measures to minimize the risks of business relations with unreliable counterparties and involvement of the Company "TIMOSHA" and (or) its employees and (or) members of management bodies in corrupt actions. For these purposes, the Company "TIMOSHA" conducts a study of the business reputation and reliability of counterparties; includes anti-corruption clauses in contracts, contracts, letters, and other documents that consolidate, among other things, relations with business partners of the Company "TIMOSHA";

• The Company "TIMOSHA" conducts a study of the business reputation and reliability of candidates for vacant positions of the Company "TIMOSHA". When applying for a job, each employee of the Company "TIMOSHA" is obliged to familiarize himself (under signature) with the internal regulatory documents of the Company "TIMOSHA";

Duties of employees of the Company "TIMOSHA"   

7.2.4. Employees of the Company "TIMOSHA" must comply with the norms of the Russian anti-corruption legislation established, inter alia, by the Criminal Code of the Russian Federation, the Code of Administrative Offences of the Russian Federation, the Federal Law of the Russian Federation of 25.12.2008 N273-FL "On Countering Corruption" and other regulatory acts of the Russian Federation in the field of countering corruption.

7.2.5. Employees of the Company "TIMOSHA" must comply with the norms contained in the internal documents of the Company "TIMOSHA" aimed at preventing and minimizing corruption risks.

7.2.6. Employees of the Company "TIMOSHA" must report all risks and facts of corruption to their immediate supervisor, in his absence to his deputy or Management.

7.3. Fair competition

7.3.1. The Company "TIMOSHA" builds relations with competitors on the principles of mutual respect, refrains from unfair competition, unethical methods of obtaining competitive advantages and abuse of position, trying to resolve possible disagreements through bona fide negotiations and mutually beneficial solutions.

7.3.2. When concluding contracts, the Company "TIMOSHA"  strives to fairly distribute risks between the parties and refrains from including provisions in contracts that unreasonably restrict competition.

It is implemented in the Company "TIMOSHA"   

7.3.3. The Company "TIMOSHA" does not provide the media and the investment community:

• Unsubstantiated negative comments about the activities of TIMOSHA's competitors and business partners;

 7.3.4. In accordance with the internal regulatory documents of the Company "TIMOSHA" regulating procurement activities, the principles of the Company "TIMOSHA" in the field of procurement are:

• The principle of competition is implemented through the implementation of procedures aimed at creating a reasonable level of competition among potential suppliers;

• The principle of economic feasibility - implemented through the assessment of the need for procurement from the point of view of economic feasibility at any stage of procurement activities;

• The principle of openness in relations with suppliers - implemented through the use of competitive procedures as a priority form of procurement;

• The principle of transparency of the procurement procedure is implemented through the possibility of monitoring and controlling procurement activities at any stage.

Duties of employees of the Company "TIMOSHA"  

7.3.5. Employees of the Company "TIMOSHA" are obliged to avoid statements discrediting the business reputation of competing companies and business partners - they should not unreasonably criticize their actions, products and services.

7.4. Interaction with public authorities and civil servants

7.4.1. The Company "TIMOSHA" and its employees strive to build and maintain constructive, open and maximally transparent relations with public authorities and civil servants in a format that does not allow conflicts of interest.

7.4.2. The Company "TIMOSHA"   refrains from gifts and payment of any expenses for government employees and their close relatives (or in their interests) in order to obtain commercial advantages in specific projects of TIMOSHA Company, including expenses for transportation, accommodation, entertainment, PR campaigns, etc.

How it is implement in the Company "TIMOSHA"   

7.4.3. Coordination of work with public authorities, except in situations where the internal regulatory documents of the Company "TIMOSHA" provide otherwise, is the competence of the responsible employees of the Company "TIMOSHA", who are responsible for the formation of mechanisms and implementation of interaction with public authorities for the effective promotion of the position and protection of the interests of the Company "TIMOSHA".

7.6. Identification and settlement of conflicts of interest

7.6.1. In accordance with the legislation of the Russian Federation, the internal regulatory documents of the Company "TIMOSHA" and the employment contracts of the employees of the Company "TIMOSHA", the employees of the Company "TIMOSHA" are obliged to act in good faith and reasonably in the interests of the Company "TIMOSHA" when performing their work functions and official duties. One of the key conditions for the conscientious performance by TIMOSHA employees of their work functions and official duties is the absence of a conflict of interests.

7.6.2. A conflict of interest arises or may arise when the personal interests of any employee of the Company "TIMOSHA", including financial, family, friendly or other, affect or may affect the conscientious performance of his official duties or lead to the use of his official position in the Company "TIMOSHA" for the purpose of obtaining benefits or advantages for yourself or other persons in connection with the discrepancy of interests with the interests of the Company "TIMOSHA". For example, when employees of the Company "TIMOSHA":

• may use their official position in the Company "TIMOSHA" to obtain benefits in the form of money, valuables, other property, other goods or services (including travel, recreation, treatment, attending entertainment events or benefits expressed in achieving personal goals, even if such benefits do not entail material benefits) for yourself, your close relatives*, friends and/or other persons;

*Close relatives are understood as parents, spouse, children, full and half siblings, adoptive parents and adopted children.

• may use business opportunities, assets, property and/or information of the Company "TIMOSHA" for personal purposes;

• compete with the Company "TIMOSHA", including competition on transactions and projects, in the personal interests or interests of close relatives, friends or third parties;

• have significant participation** (in the form of ownership or other right in relation to shares or shares, etc.) in an organization that is a competitor of the Company "TIMOSHA" or a party to a significant judicial or arbitration dispute with the Company "TIMOSHA" (Significant participation for the purposes of this Code of Ethics means, including ownership more than 25% of shares or an investment in capital in the amount of more than 25% of the total value of employees' property);

• have a significant participation (in the form of ownership or other right in relation to shares or shares, etc.) in an organization that is a counterparty of the Company "TIMOSHA", if, by virtue of their official position, employees of the Company "TIMOSHA" have the opportunity to make decisions or influence decision-making in relation to such a counterparty;

• are an employee, consultant, agent, representative, service provider, manager, including sole executive body, member of the management bodies or committee of the counterparty organization and/or competitor and /or a party in a significant judicial or arbitration dispute with the Company "TIMOSHA", or another organization whose interests are likely to enter into in conflict with the interests of the Company "TIMOSHA";

• receive loans or guarantees for personal obligations on non-market terms from any company or conclude any financial transactions with any company that is a counterparty or competitor of the Company "TIMOSHA", or a party to a significant judicial or arbitration dispute with the Company "TIMOSHA";

• receive borrowed funds from the Company "TIMOSHA" on non-market terms, as well as carry out any other actions that violate the motivation system in force at the Company "TIMOSHA", without obtaining the prior approval of the authorized bodies or the General Director of the Company "TIMOSHA";

• are or have been for 2 previous years a state/municipal employee, an official of a public authority or an employee of an organization with prevailing state/municipal participation or an employee of an organization in which the state or municipality has the right to a golden share;

• participate in commercial and/or economic activities that may negatively affect the performance of their official duties by an employee of the Company "TIMOSHA", or which entails the use, for the benefit of a third party, of assets and resources of the Company "TIMOSHA", insider information and confidential information obtained while working at the Company "TIMOSHA";

• have close relatives subordinate to the Company "TIMOSHA" and/or are themselves subordinate to them;

• make decisions, or may influence decision-making on transactions with counterparties with whom TIMOSHA employees have personal, business or other interests and relationships (including work in the counterparty organization in previous years);

• carry out their own transactions with securities, financial instruments, currency or commodities using insider or other confidential information obtained while working at the Company "TIMOSHA";

• combine executive and control functions in the Corporation, allowing them to use their job responsibilities for personal gain;

• initiate, coordinate or participate in the procedure for hiring the Company "TIMOSHA", determining job responsibilities, bonuses, salary increases, providing benefits, financial assistance, etc. for their close relatives.

How it is implemented in the Company "TIMOSHA"

7.6.3. The Company "TIMOSHA" uses legal means and monitors, identifies and settles situations that are or may be a conflict of interest, and has the right to demand from TIMOSHA Company employees the settlement of such situations if they pose a threat to the interests and/or reputation of the Company "TIMOSHA", to influence the proper and conscientious execution the labor obligations of employees may be the cause of corruption risks.

7.6.4. The Company "TIMOSHA", using legal means, has the right to check the reliability of employees when hiring.

7.6.5. In all cases, the conflict of interests is settled by the Company "TIMOSHA" in compliance with the requirements of the labor legislation of the Russian Federation, taking into account the balance of interests of the Company "TIMOSHA" and its employees.

Duties of employees of the Company "TIMOSHA"  

7.6.6. Employees of the Company "TIMOSHA" are obliged to minimize the risks of a conflict of interest, including avoiding situations in which there is or may be:

• a contradiction between the personal interests of the employee and the interests of the Company "TIMOSHA";

• employees use their official position in the Company "TIMOSHA" in order to obtain benefits or advantages for themselves, their relatives, friends or other persons;

• circumstances affecting the conscientious and impartial performance by employees of their official duties in the Company "TIMOSHA".

7.6.7. Employees of the Company "TIMOSHA" when making decisions on issues arising in connection with their work in the Company "TIMOSHA", are obliged to:

• be guided by the interests of the Company "TIMOSHA";

• avoid any situations that are or may be a conflict of interest;

• act in such a way that personal interests, family ties, friendships, personal likes and dislikes do not affect the objectivity and impartiality of managerial and business decisions made in connection with work at the Company "TIMOSHA";

• immediately inform their immediate supervisor in writing about the occurrence of a potential or actual conflict of interest with the Company "TIMOSHA" and assist in resolving the conflict of interest;

• be responsible for:

• non-compliance or improper compliance with the interests of the Company "TIMOSHA" in a conflict of interest situation;

• concealment of the presence of a conflict of interest from the Company "TIMOSHA";

• failure to take measures or refusal to take actions to prevent and/or resolve conflicts of interest.

7.6.8. If at any time an employee of the Company "TIMOSHA"  reasonably believes that he has or may have a conflict of interests, then such employee is obliged to immediately send to the Directorate for the Protection of Resources a completed and signed Declaration on "Ethics and Conflict of Interests" (in the form of Appendix 1 to this Code of Ethics) and in in the future, to provide assistance for the prompt settlement of conflicts of interest in accordance with the recommendations and requirements of the Company "TIMOSHA" and the legislation of the Russian Federation.

7.6.9. An employee of the Company "TIMOSHA" who has a conflict of interest, before resolving such a conflict of interest, is recommended to refrain from making individual decisions and from participating in voting when making collegial decisions on the issues of the TIMOSHA Company's activities related to the source of the specified conflict of interest. Prior to the settlement of the conflict of interests, decisions on the activities of the Company "TIMOSHA"   related to the source of the specified conflict of interests (for example, the conclusion of transactions, selection of suppliers, negotiation, etc.) are made by another person or a collegial body of the Company "TIMOSHA" , endowed with appropriate powers by internal documents of the Company "TIMOSHA". The resolution of the specified conflict of interests takes place in the usual manner, as stipulated in paragraphs 4.7. - 4.8. of this Code.

7.6.10. If any employee of the Company "TIMOSHA" doubts the correctness of his assessment of the presence or absence of a conflict of interests, or how such an assessment should be carried out, he is obliged to immediately seek clarification from the Directorate for the Protection of Resources of the Company "TIMOSHA"

7.7. Proportionality of representation expenses and business gifts

7.7.1. In accordance with the Anti-Corruption Policy of the Company "TIMOSHA", gifts and representation expenses, including business hospitality, which employees on behalf of the Company "TIMOSHA" can provide to other persons and organizations, or which employees, in connection with their work at the Company "TIMOSHA", can receive from other persons and organizations, must meet the totality of all the criteria listed below:

• be directly related to the legitimate goals of the Company "TIMOSHA", for example, with the presentation or completion of business projects, successful execution of contracts, or with generally accepted holidays, such as Christmas and New Year, International Women's Day, memorable dates, anniversaries;

• be reasonably reasonable, proportionate and not be luxury items;

• do not represent a hidden reward for a service, action, inaction, connivance, patronage, granting of rights, making a certain decision on a transaction, agreement, license, permit, etc. or an attempt to influence the recipient for another illegal or unethical purpose;

• not to create reputational risk for the Company "TIMOSHA", employees of the Company "TIMOSHA" and other persons in case of disclosure of information about gifts or representative expenses;

• not contradict the principles and requirements of this Code of Ethics, other internal documents of the Company "TIMOSHA" and the norms of applicable legislation.

7.7.2. The HR Department of the Company "TIMOSHA" brings to the attention of all employees of the Company "TIMOSHA" the provision of the Code of Ethics of TIMOSHA, including the definition of what is acceptable and unacceptable in terms of business gifts and business hospitality, as well as ways to inform about violations key principles concerning business gifts and representative events.

7.7.3. It is not allowed to receive gifts, as well as giving gifts on behalf of the Company "TIMOSHA", its employees and representatives to third parties in the form of cash, cash or non-cash, in any currency.

7.7.4. Business gifts from the Company "TIMOSHA" or its managers and/or employees at the expense of TIMOSHA Company for representatives of public authorities and civil servants of any countries of the world. As well as representative and other related expenses when interacting with representatives of public authorities and civil servants of any countries of the world, are allowed only in cases and within the limits provided for by the legislation of the Russian Federation, applicable norms of foreign legislation and internal regulatory documents of the Company "TIMOSHA".

Duties of TIMOSHA employees

7.7.5. Promptly inform their Supervisor and the Company's Management about non-compliance with key principles related to business gifts and representative events.

7.7.6. In case of doubts about the appropriateness of a business gift, holding/ attending an entertainment/representative event or business hospitality, TIMOSHA employees should seek advice from their direct Supervisor or the Company's Management.

7.8. Protection of confidential information

7.8.1. Employees of the Company "TIMOSHA" who have access to confidential and/or insider information of the Company "TIMOSHA", personal data of employees and clients of the Company "TIMOSHA", must use such information only in connection with the performance of their official duties and have the right to disclose it to other employees of the Company "TIMOSHA", contractors or other persons only on the principle of official necessity, and subject to certain rules, restrictions and conditions specified in the regulatory documents of the Company "TIMOSHA".

7.8.2. All employees of the Company "TIMOSHA" are obliged not to disclose, comment in the media, and not to transmit such information (including after termination of employment relations with the Company "TIMOSHA") to any companies and persons (including relatives), except in cases when its disclosure, commenting or transmission is authorized by the authorities management and internal documents of the Company "TIMOSHA" or required by law.

How it is implemented in the Company "TIMOSHA" 

7.8.3. Detailed information about the policy of the Company "TIMOSHA" in the field of information protection is provided in the internal regulatory documents of the Company "TIMOSHA" on working with personal data.

Duties of employees of the Company "TIMOSHA" 

7.8.4. Employees of the Company "TIMOSHA" are obliged to keep confidential any confidential information, not to disclose its contents, both during the entire period of work in the Company "TIMOSHA", and after dismissal. Employees have the right to disclose confidential information only with the prior permission of the management or in accordance with the procedure established by the internal documents of the Company "TIMOSHA".

7.9. Use of TIMOSHA Company's property

7.9.1. Employees are obliged to take care of TIMOSHA Company's property and assets and ensure their effective use for legitimate business purposes, preventing property risk leading to losses and damage to the business reputation of the Company "TIMOSHA".

7.9.2. The property and assets of the Company "TIMOSHA" include tangible assets, cash, intellectual property rights, know-how, business process data, network resources, as well as written correspondence and information transmitted and received by e-mail and other communication systems Companies "TIMOSHA" or stored in them.

How it is implemented in the Company "TIMOSHA"

7.9.3. In the Company "TIMOSHA" internal regulatory documents describe the requirements for the use and security of property, including:

• personal responsibility of the Company "TIMOSHA" employees for ensuring the safety of TIMOSHA Company's property, which they received for use, and the need to inform about all cases of improper treatment of TIMOSHA Company's property by other persons;

• protection of TIMOSHA's funds from misuse, loss, fraud and theft.

7.9.4. The Internal Audit Department and the Company's Management conduct periodic inspections of the use of TIMOSHA's property and assets for compliance with the stated goals and norms of this Code of Ethics and other internal documents of the Company "TIMOSHA".

Duties of the Company "TIMOSHA" employees

7.9.5. Each employee of the Company "TIMOSHA" is responsible for the safety and proper use of the property and assets of the Company "TIMOSHA".

8. Making changes

8.1. In case of changes in the requirements of Russian and foreign legislation or applicable norms of international law, best practices, interests of the Company "TIMOSHA" or its shareholders, investors, partners, creditors, as well as in case of identification of insufficiently effective provisions of this Code of Ethics and in other cases, the Management of the Company "TIMOSHA" may amend the Code of Ethics and additions that should not distort the high business standards of the Company "TIMOSHA".

9. Liability for non-performance (improper performance) Code of Ethics

9.1. Employees, regardless of their position, may be personally liable for non-compliance with the principles and requirements of this Code of Ethics, as well as for the actions (inaction) of their subordinates who violate these principles and requirements with their knowledge or connivance.

9.2. If necessary, the issue of violation by an employee of the Company "TIMOSHA" of this Code of Ethics and his responsibility may be submitted to the management of the Company "TIMOSHA" for consideration.

9.3. Persons who have committed or committed actions (inaction) that violate the requirements of this Code of Ethics, if there are grounds, may be brought (depending on the circumstances and nature of the violation) to disciplinary, administrative, civil or criminal liability, including at the initiative of the Company "TIMOSHA".

10. Conclusion

10.1. The Code of Ethics is not an exhaustive set of rules and cannot provide recommendations for all possible situations that TIMOSHA employees may encounter in the course of performing their official duties and doing business with TIMOSHA.

10.2. If necessary, make an ambiguous business decision in a situation not directly provided for by the Code of Ethics, each the employee is obliged to ask himself the following questions:

• Is it legal?

• Is it fair and right?

• Does this meet the interests of the Company "TIMOSHA"?

• Does this comply with the ethical principles and values of the Company "TIMOSHA"?

• Will this negatively affect the reputation of the Company "TIMOSHA" with a high level of business ethics?

• Do I have the authority?

• Will my actions be a good example for other TIMOSHA employees?

• Will I feel comfortable if the shareholders and the management of the Company "TIMOSHA" find out about my actions, or will the relevant information be published in the media?

10.3. If the answer to any of these questions is negative, or you have any questions in connection with the interpretation or application of the Code of Ethics, then you should immediately discuss the situation with the immediate supervisor or the Management of the company.