“Foreign Official” under the FCPA means “any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality, or for or on behalf of any such public international organization”. “Government Official”, in terms of Russian law, is a Russian citizen holding a Government Service post. Government Service means professional activity in ensuring the execution of powers of: - the Russian Federation, or of the federal state bodies; - the constituent entities (regions) of the Russian Federation, or of the state bodies of the constituent entities (regions) of the Russian Federations; or - the officials filling the state posts of the Russian Federation, established by the Russian Constitution and federal laws (i.e. the President, the Prime Minister); - the officials filling state posts of the constituent entities (regions) of the Russian Federation, established by the constitutions, statutes and laws of the constituent entities (regions) of the Russian Federation (e.g. Governor).

Government Service includes: Civil Service Military Service Law-enforcement Service Civil Service is divided into Federal Government Civil Service and Regional Government Civil Service. Military Service and Law-enforcement Service belong to the category of Federal Government Service. Government Service Posts are listed in the Registries of the Government Officials Government Service vs. Municipal Service

Russian Limited Liability Company: finding the information in the Extract from the Single State Registry of Legal Entities and Individual Entrepreneurs kept by the tax authorities. The information on the registered owners of a Limited Liability Company is available to the public. Russian Joint Stock Company: finding the information in the Registry of shareholders which is kept either by the Company itself, or by a Professional Registrar. A Joint Stock Company may keep the registry itself provided it has no more than 50 shareholders. Limited access to the information: the information may be provided to the Company itself, to the registered owners of shares and nominees, or to the competent authorities.

1.“Conflict of Interest”. 2.Disclosure of information on the amount of profit, property and financial obligations. 3.Disclosure of information on attempts to corrupt the Government Official. 4.Restriction regarding further employment.

1.“Conflict of Interest” is a situation when the personal interest of a Government Official (which may be direct, or indirect) may affect proper fulfillment by such official of his/her obligations and when there is or may be a contradiction between the Personal Interest of the Government Official and the rights and lawful interests of citizens, entities, organizations, society and State, in the result of which the rights and interests of the latter may be injured. “Personal Interest of a Government Official” shall mean the possibility to receive, in the course of performing the official functions, profit in the form of monetary funds, valuables, other property, or services of financial nature, property rights.

Measures meant to prevent the “Conflict of Interest”: - Prohibition to do business or carry on any other commercial activity; - Obligation to notify a senior official on an existing, or a potential “Conflict of Interest” and to follow the instructions of such senior official given in order to avoid the “Conflict of Interest” or negative consequences thereof; - Recusal of the Government Official; - Obligation of a Government Official to transfer into trust management the securities, shares, or participatory shares in the Charter capital of a legal entity in case of a potential “Conflict of Interest”.

Liability: - Disciplinary punishment may be imposed on a Government Official for failure to notify on the existing, or potential “Conflict of Interest”, or for failure to take measures meant to prevent the “Conflict of Interest” or avoid negative consequences thereof. - Criminal Liability may be imposed on a Government Official for the abuse of the official powers done out of mercenary or any other personal interest, when such abuse has involved substantial violation of rights and lawful interests of individuals, organizations, society, or the State (art. 285 of the Russian Criminal Code).

2.Obligation to disclose to the employer or to the future employer information on the amount of profit, property and financial obligations. Liability for failure to provide information or for provision of inaccurate or misleading information: Refusal to hire; dismissal, or another form of disciplinary punishment.

3.Government Official’s obligation to inform the employer, prosecutor’s office, or other competent state bodies on any attempts to corrupt him/her. Liability for failure to comply:Dismissal

4.Within 2 years after resignation from Government Service, prior approval by a competent state commission is required for the ex-Government Official to be hired by a commercial or a non-commercial organization, previously managed or controlled by such Government Official. The employer of a person, who has resigned from Government Service less than 2 years before being hired by such employer, is obliged to inform the state authorities on the conclusion of a Labour contract with such person within 10 days of its conclusion. Liability for failure to comply: Termination of the Labour contract signed between the ex-Government Official and his/her new employer. The liability of the employer for failure to comply with its notification obligation may consist in imposing on such employer of an administrative fine in the amount of up to 500,000 Russian Roubles (around $ 13,890).

Obligation to disclose information on the amount of profit, property and financial obligations of the spouses and minor children of Government Officials. Verification of the provided data and liability for failure to comply. “Personal Interest of a Government Official” and “Conflict of Interest” are in place when profit is received by the members of the Government Official’s family (spouse, children, brothers, sisters, parents-in-law, step children, brothers-in-law, or sisters-in-law), or by individuals or legal entities in respect of which the Government Official has financial or other obligations.

Role of certain state bodies in fighting corruption: - Account Chamber of the Russian Federation; - Federal Security Service of the Russian Federation; - Prosecutor’s Office; - Ministry of Home Affairs; - Anti-corruption Council with the President of the Russian Federation. Commissions for fulfillment of requirements to professional behavior of Civil Service Agents and for resolution of the Conflicts of Interest: establishment and functioning.