Ethical principles of the fight against corruption of the “Dori-Darmon” JSC

Chapter 1 General provisions

1. These Rules are developed in accordance with the decision of the Cabinet of Ministers of the Republic of Uzbekistan №62 of March 2, 2016 “On approval of the standard rules of ethical conduct of employees of public administration and executive authorities in the field”, and establish the rules and principles of professional etiquette, rules of conduct in service of employees of “Dori-Darmon” JSC (hereinafter - the Company).
2. These rules are aimed at preventing offenses, eliminating the causes and conditions of their occurrence, educating employees in the spirit of high legal consciousness, strict compliance with the Constitution and other normative legal acts of the Republic of Uzbekistan.
3. Employees of the Company and its structural organizations are obliged to comply with the requirements of these rules. The obligation to know and comply with these rules applies to all employees of the Company and its structural organizations, regardless of the position held and the nature of the work performed.
4. Measures taken as part of managing conflicts of interest in the Company and its structural organizations are set forth in the Regulations on Managing Conflicts of Interest in the Company System.
5. If employees of the Company and its business units have any questions about these rules, professional conduct or Company procedures, they may seek advice from Compliance Control and the Company Helpline. 

Chapter 2: Basic Terms and Concepts

1. The following basic concepts are used in these Rules:

close relatives - persons related by a relative or matchmaker, i.e. parents, siblings, married couple, child, including stepchildren, grandparents, grandchildren, and parents, siblings, and stepbrothers;

kinship - The personal interest of a Company employee in the form of subjective, privileged and prejudicial treatment of third parties on the basis of belonging to the same dynasty, with the same ancestors;

conflict of interest - a situation in which a personal (direct or indirect) interest of an employee of the Company and its structural organizations affects or may affect the proper performance of his or her official duties, and in which a conflict arises or may arise between the interests of the Company and its structural organizations and the personal interest of the employee;

corruption is the unlawful use by a person of his position or office for the purpose of obtaining a material or non-material benefit for his personal benefit or the benefit of others, as well as the unlawful use or granting of this benefit;

corruption offence - an act that has signs of corruption, for which the legislation of the Republic of Uzbekistan provides for liability;

counterparty - any legal entity or individual who enters into a contractual relationship (with the exception of labor relations) with the Company and its structural organizations; 

personal interest of an employee - the possibility of personal benefit of an employee of the Company and its structural organizations in the form of money, tangible or intangible values, other property, wealth and benefits (personal, social, financial, political and other commercial and non-commercial interests) in performing their official or official duties at the proper level, which may be influenced by a close relative or related persons;

mestnichestvo - the hiring, rotation and appointment of a person to a position without regard to the qualification requirements for the position solely because of his kinship (fame or popularity of a relative among the people and his public recognition) and the official status of relatives in the authorities;

nepotism (close kinship, nepotism; a form of favoritism based on family ties) - the use and/or influence of power to provide illegal benefits to one's close relatives or friends, as well as the unjustified reward of close relatives and (or) friends to the detriment of the interests of the Company by accepting and appointing close relatives and friends to the position;

patronage - protection of an employee of the Company in the form of creating favorable working conditions by another employee holding a higher position, with the acceptance of his side;

company employee - a person who has entered into an employment relationship with the Company and its structural organizations;

favoritism is when a Company employee prioritizes the interests of one person or group over those of another person and/or group, selects and places personnel in the Company, promotes, awards monetary bonuses and recommends for state awards, provides vacations or sends to resorts and foreign trips, and does not follow order in cases involving turnover, work schedules and duty assignments; 

Chapter 3. Basic principles and rules of behavior in the service

7. Employees of the Company and its structural organizations shall perform their official duties on the basis of the following principles:

legality - employees of the company and its structural organizations unconditionally comply with the legislation of the Republic of Uzbekistan and fulfill their official obligations in accordance with job descriptions, employment contracts, internal documents and the legislation of the Republic of Uzbekistan;

priority of rights, freedoms and legitimate interests of citizens - the rights, freedoms and legitimate interests of citizens are the highest value of the Company and its structural organizations. Employees of the Company and its structural organizations do not allow violations of the rights, freedoms and legitimate interests of citizens and assist in their restoration in cases of violation of the law. 

patriotism and fidelity to duty - Employees of the Company and its structural organizations carry out their activities on the basis of spiritual-patriotic values, fidelity to the homeland, fidelity to duty, expressing the requirements of society to the Company. Employees of the Company perform their official duties regardless of personal benevolence, their own interests and ideological views;

fidelity to the interests of the state and society - Employees of the Company and its structural organizations must refrain from any actions associated with the influence of personal interest that prevents them from performing their duties in good faith and pursuing the interests of the state and society;

fairness, honesty and objectivity - Employees of the Company and its structural organizations ensure fair, honest and objective treatment of all persons who apply to the Company;

professionalism and competence - Employees of the Company and its structural organizations are the main value of the Company; their qualifications, trust, good intentions, cooperation and team spirit allow achieving the set goals and improving the Company and its structural organizations. Employees of the Company and its structural organizations are obliged to ensure professionalism, impeccable business reputation, assistance in creating a favorable cordial atmosphere in the team, as well as effective exchange of knowledge and experience with colleagues;

efficiency and frugality - the company and its structural organizations constantly consider improvement of the system of interrelations with internal management, citizens, organizations and state bodies, introduction of innovative technologies and in other ways, as one of the strategic tasks, achievement of which allows increasing the efficiency of its activity, including increasing the welfare of society and the state. Employees of the company and its structural organizations, in their turn, responsibly and carefully treat the company's property, time of their own and other employees. 

Chapter 4. The Company's role in forming the moral behavior of subordinate employees

1. Managers of the Company and its structural organizations must observe the following when shaping the moral behavior of employees:

- demonstrate personal example of unconditional compliance with the moral standards and principles set forth in these Rules in the performance of his/her official duties;

- to be honest with employees of the Company and its structural organizations, to respond to their suggestions, ideas, demands and complaints in a timely manner;

- avoid discriminatory policies and guarantee employees equal rights and opportunities in pay and career development;

- creating conditions for employees that are not harmful to their lives and health;

- establishing relations with employees of the company and organizations in its system on the basis of long-term cooperation, common purpose, respect and consideration of mutual interests, and social partnership;

- take initial steps to prevent conflicts of interest in a timely manner;

- take measures to prevent corruption and to protect and encourage employees who actively participate in the fight against corruption;

- clearly define the range of tasks and distribute among subordinate employees, based on their career and professional abilities, not to give tasks that go beyond the job description of employees;

- unreasonably reward an employee and prevent him or her from being promoted, and take action against disregarding excessive actions (e.g., employees taking insufficient action to correct deficiencies in their performance);

- not allow workers to participate in forced labor, including the improvement of urban areas, seasonal agricultural work, scrap metal collection, as well as other seasonal activities (except in cases where, according to the stop of the President of the Republic of Uzbekistan or the Cabinet of Ministers, voluntary Saturday work is organized on the territory of the relevant organization in strict compliance with safety standards);

- effective management of employees of the Company and its structural organizations, control over their careful and economical attitude to the Company's property and financial resources;

- be responsible for the inaction of subordinate employees in preventing violations of these Rules.

1. Managers of the Company and its structural organizations, as well as heads of departments and divisions of the Company in their relations with subordinate employees should be an example of professional, honest and fair behavior, create a favorable working environment and promote a positive spiritual and psychological atmosphere in the Company.
2. Managers of the Company and its structural organizations, as well as heads of departments and divisions of the Company must not allow the hiring, rotation, appointment, promotion or punishment of employees according to nepotism, favoritism, localism, patronage, kinship and on other grounds, and must not tolerate subjective attitudes toward them. 

Chapter 5: Employee Obligations to Comply with Ethical Standards and Rules

11. Employees of the company and its structural organizations shall, in the performance of their official duties:
    • comply with the Constitution and laws of the Republic of Uzbekistan, decrees, resolutions and orders of the President of the Republic of Uzbekistan, resolutions and orders of the Cabinet of Ministers of the Republic of Uzbekistan, decisions of the Supervisory Board of the Company, orders of the Chairman of the Company, internal departmental documents of the Company;
    • to perform their duties conscientiously and professionally;
    • to execute in a timely and qualitative manner the orders issued by superior state bodies and officials within the limits of their authority;
    • to conduct its activities within the competencies specified in the legislation and internal documents;
    • not discriminate against citizens and others in the performance of their official duties, maintain their independence from their influence, and take into account the rights, obligations and legitimate interests of citizens;
    • refrain from actions that may interfere with the performance of official duties or that may be in any personal, proprietary or other interests in the performance thereof;
    • continuously develop the knowledge and skills necessary to perform their job duties effectively;
    • not to use their powers to unlawfully interfere in the activities of government bodies, other organizations or their officials;
    • respect the customs and traditions of the peoples of the Republic of Uzbekistan and other countries, taking into account the cultural and other characteristics of different ethnic, social groups and religions, contributing to social stability, inter-ethnic and interfaith harmony;
    • refrain from behavior that may cause employees to be suspicious of the integrity of their job duties and prevent situations that may threaten their credibility or the reputation of the Company and its structural organizations;
    • regardless of their position, gender, race, nationality, language, religion, social origin, religion, personality and social status, have a high level of spiritual and moral qualities, treat colleagues, citizens and other persons with respect, courtesy and kindness;
    • respect the activities of media representatives in order to inform the public about the work of the Company and its structural organizations, and contribute to obtaining reliable information in accordance with the established procedure;
    • ensure that confidential information is used only for business purposes and that it is adequately protected against the risk of destruction, loss, alteration, disclosure, damage, and unauthorized use of confidential information and personal information;
    • avoid abusive, disrespectful and discriminatory behavior, as well as the spreading of cruel or false rumors that undermine the reputation of the Company and its structural organizations and (or) the authority of their employees;
    • ensure that pharmacy employees dress appropriately and keep the workplace clean and orderly;
    • in the performance of his or her official duties, use the Company's office rooms, state property, facilities and other property for official purposes only;
    • in the Company and its structural organizations to comply with the established rules for the delivery and receipt of official messages;
    • of cases of incitement to commit offenses, as well as the facts of any offenses committed by other employees of the Company and its structural organizations and any other offenses known to him, immediately report to his supervisor or other authorized persons;
    • provide the necessary practical and methodological assistance to new and other employees of the Company and its structural organizations, and support the professional aspirations of colleagues;
    • to observe work discipline and to use work time effectively;
    • refuse to consume alcohol, drugs or other illegal substances in the workplace and/or in the performance of their duties, and not to be in the workplace under the influence of alcohol or drugs;
    • correctly perceive criticism from colleagues and others, change the model of behavior when receiving objective reproaches;
    • be in a calm emotional state, which has a positive impact on the execution of tasks.

1. Compliance with political, economic objectives, as well as personal and other subjective reasons do not constitute grounds for violation of the requirements of these Rules.
2. Based on the work environment and type of service, you should assist the employee in the performance of his or her duties, observe generally accepted work practices, and emphasize formality, modesty, and discipline.
3. Employees shall observe generally accepted standards of morality and refrain from conduct contrary to morality in their leisure time. 

Chapter 6. Gifts and signs of hospitality in communication

1. Employees of the Company and its structural organizations in the course of their work related to the performance of their official duties may not accept any gifts or hospitality from individuals and legal entities, means of promotion in the form of debt, guarantees, sureties, rewards, cash or cash equivalents, material assistance in the form of securities. 
2. Gifts given to employees of the Company and its structural organizations on holidays related to their personality (birthdays, births of children, Motherland Defender's Day, International Women's Day, etc.) not related to the performance of official duties shall be recognized as gifts related to the employee's personality.
3. The following requirements must be met when giving such gifts:

• Gifts should be given with the participation of at least three co-workers;
• The gift-giving process should be accompanied by a congratulatory speech, in which the event that gave rise to the gift should be clearly expressed;
• the total value of the gift (including all taxes and fees) must not exceed five (5) times the basic calculation amount;
• one Company employee's expenses for a gift to another employee may not exceed one (1) multiple of the base calculation amount.

1. In any case of suspicion of the legality of receiving a gift, employees should familiarize themselves with the rules of the Company's Anti-Corruption Policy and seek advice from Compliance Control.
2. The giving and receiving of gifts and hospitality in the workplace is regulated by the Anti-Corruption Policy in the system of the “Dori-Darmon” JSC. 

Chapter 7: Fighting Corruption

1. The Company and its structural organizations do not tolerate corruption in any of its forms and manifestations.
2. Based on the principle of “zero tolerance” for corruption, all employees of the company and its structural organizations are strictly forbidden to participate in any actions related to corruption, i.e. to act or not to act in the interests of the briber, directly or indirectly, personally or through third parties, to demand a bribe, money, securities, other property, services in pecuniary form, committing fraud, making promises and taking bribes, being an intermediary in giving and (or) accepting bribes, receiving payment for simplification of formalities, accepting bribes from another person or illegal use of one's official position for other selfish purposes.
3. The anti-corruption principles and requirements adopted by the Company and its structural organizations are set forth in the Anti-Corruption Policy of the “Dori-Darmon” JSC System. 

Chapter 8: Ethics Commission

1. Ethics commissions (the Ethics Commission) shall be established to review compliance with these Rules, as well as generally accepted standards of ethics in the Company and its structural organizations.
2. The Ethics Commissions shall conduct their activities on the basis of the Regulations on Ethics Commissions, these Rules adopted by the Company and its structural organizations, as well as in accordance with the orders of the Company's management.
3. Ethics commissions consider issues related to violations of ethics rules and the Conflict of Interest Management Regulations by employees of the Company and its structural organizations:  

• at the direction of the President;
• based on the results of a performance review;
• on their own initiative;
• on the basis of information received from employees of the Company and its structural organizations, as well as through their communication channels.

1. In the event of a violation or suspected violation of these Rules by employees of the Company and its structural organizations, the distribution of powers (functions) to address the situation between the relevant departments shall be as follows:

• If a conflict of interest is discovered in the “Dori-Darmon” JSC system that has not been resolved in accordance with the procedure stipulated in the Regulations on Conflict of Interest Management, this situation shall be reviewed by the Ethics Commission together with the Compliance Control Service of “Dori-Darmon” JSC;
• If corruption offenses or situations of corruption risk are identified, they are reviewed by the Company's Compliance Control Service;
• In the event of violations of the rules regarding gifts and hospitality in the treatment of work, these situations are handled by the Company's Compliance Department;
• If the offenses concern not only the Rules, but also other internal documents of the Company that provide for the direct participation of the Compliance Control Service of the Company at the meetings of the Ethics Commission, in this case the facts of violations of these Rules and the occurrence of risks shall be considered by the Compliance Control Service together with the Ethics Commission of the Company.

In other cases not covered by this paragraph, violations of the requirements of this Policy shall be reviewed by the Ethics Committee. 

Chapter 9. Reporting ethics violations

1. If there is any suspicion about the legality and/or morality of the actions of employees of the Company and its structural organizations, the existence of a possible violation of ethics rules or a reasonable assumption of their violation, they may report this via the Company's existing communication channels.
2. The Company and its structural organizations, within the limits of their authority and available capabilities, ensure the secrecy of the person who reported the information about the violation, except in cases stipulated by the legislation of the Republic of Uzbekistan.
3. The Company and its business organizations protect the interests of their employees and ensure that they will not tolerate retaliation, including termination, reduction of position, discrimination, or harassment of employees who voluntarily report suspicious behavior by another employee or the possibility of an ethics violation in this Policy.
4. Reports of violations of these Rules may be sent through the following channels of communication:

• on the Company's Helpline;
• by calling the telephone numbers of the Company's Compliance Control employees;

- Telegram to the Company channel;

- email of the Company's Compliance Control Service.

1. All communications received through the Company's communication channels and its structural organizations shall be objectively and timely reviewed by an official of the relevant department and division in accordance with the law and the Company's internal documents.
2. Messages sent anonymously are also accepted for consideration (only through the “anonymous request” channel on the Company's official website). In this case, the addressee, who wishes to remain anonymous, agrees to the following:

• The company cannot contact the complainant to respond to the message;
• The company is unable to conduct a full and comprehensive review due to the lack of availability of additional information.

1. intentional submission of false information by an employee of the Company and its structural organizations shall be considered as a violation of this Anti-Corruption Policy and an example of immoral behavior, and such person may be held liable in accordance with the laws of the Republic of Uzbekistan and internal documents of the Company. Detailed information about the operation of communication channels and the order of consideration, processing of the received messages is reflected in the rules of reception and processing of messages coming from the communication channels in order to inform the Company of corrupt practices, as well as in similar internal documents of the Company. 

Chapter 10. Liability for violation of these rules

1. Employee compliance with this Policy is considered an important professional competency and serves, among other criteria, promotion, performance evaluation, etc.
2. Commitment to the standards of ethics of an employee of the Company and its structural organizations is taken into account during performance appraisal, when preparing a personnel reserve for appointment to higher and other positions.
3. Violation of these Rules by an employee of the Company and its structural organizations may serve as grounds for bringing him/her to account in accordance with the procedure established by law. 

Chapter 11. Procedure for revising and amending

1. In the event of changes and amendments to the principles and requirements of the applicable laws and regulations and the law enforcement practice of the Company and its structural organizations, these provisions may be reviewed and updated by order of the Chairman of the Management Board.