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APPROVED by the Resolution of the Board of Directors of OAO NOVATE Minutes No. 170 dated 1 September 2014 ANTI-CORRUPTION POLICY of OAO NOVATE 2 Contents INTRODUCTION ................................................................................................
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How to fill out an anti-corruption policy of OAO:

01
Start by reviewing the existing policies and procedures: Before filling out the anti-corruption policy of OAO, it is essential to familiarize yourself with any existing policies and procedures related to anti-corruption. This will help ensure that your policy aligns with the organization's values, goals, and legal requirements.
02
Identify and assess the risks: Conduct a thorough risk assessment to identify potential corruption risks within OAO. This may involve evaluating various factors such as interactions with government officials, business partners, or high-risk jurisdictions. Consider engaging relevant stakeholders, such as employees, compliance experts, and legal counsel, to obtain a comprehensive understanding of the risks involved.
03
Develop a clear and concise policy statement: The anti-corruption policy should clearly articulate the organization's commitment to combating corruption and promoting ethical conduct. This statement should outline the expectations, responsibilities, and consequences for non-compliance with the policy. Use clear and straightforward language to ensure that all employees can understand and follow the policy.
04
Establish preventive measures: Outline specific preventive measures and controls within the policy to mitigate corruption risks. This may include implementing robust due diligence processes for third-party engagements, establishing guidelines for gift-giving and hospitality, promoting transparency in financial transactions, and implementing whistle-blower mechanisms to encourage reporting of potential violations.
05
Provide guidance on reporting and investigations: Include clear instructions on how employees should report suspected instances of corruption and the procedures for conducting internal investigations. Ensure that the policy highlights the protection mechanisms in place for whistle-blowers and emphasizes the non-retaliation policy.
06
Promote awareness and training: Develop training programs and awareness campaigns to educate employees and stakeholders about the anti-corruption policy. The training should highlight the consequences of corruption, relevant laws and regulations, and practical examples of ethical conduct. Regularly review and update the training materials to maintain effectiveness.

Who needs the anti-corruption policy of OAO:

01
OAO employees: All employees of OAO, regardless of their role or hierarchy, should be aware of and follow the anti-corruption policy. By adhering to this policy, employees contribute to a transparent, ethical, and corruption-free work environment.
02
Third-party entities: External parties, such as contractors, suppliers, consultants, and business partners, who have interactions with OAO, should also comply with the anti-corruption policy. Establish contractual obligations and due diligence processes to ensure that these entities align with the organization's commitment to fighting corruption.
03
Stakeholders and shareholders: The anti-corruption policy demonstrates OAO's dedication to ethical conduct and transparency. Stakeholders and shareholders, such as investors, regulators, customers, and the public, have an interest in seeing OAO actively combat corruption and maintain a responsible business environment.
By having a well-developed and implemented anti-corruption policy, OAO can protect its reputation, maintain legal compliance, and contribute to a sustainable and ethical business ecosystem.
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The anti-corruption policy of OAO outlines the guidelines and procedures to prevent and detect corrupt practices within the organization.
All employees and stakeholders of OAO are required to adhere to and file the anti-corruption policy.
To fill out the anti-corruption policy of OAO, employees must carefully read the guidelines and instructions provided and make sure to follow them accurately.
The purpose of the anti-corruption policy of OAO is to promote ethical behavior, transparency, and accountability, and to prevent corrupt practices.
The anti-corruption policy of OAO must include details on how to report suspected corruption, consequences for violating the policy, and procedures for handling corruption allegations.
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