Anticorruption Policy of LLC "Global Research Partner"

1. Preamble.
This Anticorruption Policy (hereinafter referred to as the "Policy") of Limited Liability Company "Global Research Partner" (hereinafter referred to as the "Company"), recognizing the responsibility for upholding the values of the rule of law and integrity, striving to ensure sustainable development, safeguarding its business reputation, and promoting the use of fair commercial practices, and in the interests of, including but not limited to, its founders, employees, business partners, and clients, declares that its founders, management bodies, officials, and employees in their activities, as well as in their relationships with business partners, government authorities, local self-government bodies, and other legal and natural persons, are guided by the principle of zero tolerance towards corruption in all its forms and manifestations. They undertake (and will undertake) all measures to prevent, detect, and counteract corruption as provided by law and this Policy. The Company states its principled position and condemns corruption as an illegal and unethical means of conducting business.

2. General Provisions.

2.1. This Anticorruption Policy defines the principles and mechanisms for preventing, detecting, and combating corruption in the Company's activities in accordance with the requirements of current Ukrainian legislation.

2.2. The Policy is developed in accordance with the current legislation of Ukraine, international standards, and best practices in the field of anticorruption.

2.3. The goal of the Policy is to ensure compliance with requirements for preventing corruption offenses, creating conditions for the detection and effective counteraction of corruption at all levels of the Company's activities.

3. Scope of Application.

3.1. The Policy applies to all Company employees, regardless of their positions, as well as individuals undergoing training at the Company or performing certain work based on civil law contracts concluded with the Company.

3.2. All Company employees, regardless of their positions, are obligated to adhere to the principles and requirements of this Policy in the performance of their professional duties.

4. Core Principles of Anticorruption Policy

4.1. Zero Tolerance for Corruption: The Company adheres to the principle of zero tolerance for any manifestations of corruption, including bribery, kickbacks, collusion, conflicts of interest, etc.

4.2. Legality: The Company's activities are conducted in strict accordance with the legislation of Ukraine and international standards.

4.3. Transparency and Accountability: The Company seeks to ensure maximum transparency in all management processes, particularly in the management of financial resources, and holds all employees accountable for their actions.

4.4. Responsibility: All Company employees bear personal responsibility for adhering to the principles and requirements of this Policy.

5. Measures for Preventing Corruption.

5.1. Training and Awareness: The Company conducts regular training and informational events to raise employee awareness of corruption risks and ways to avoid them.

5.2. Risk Assessment: The Company periodically conducts assessments of corruption risks in its activities and implements measures to mitigate them.

5.3. Policy on Gifts and Representational Expenses:

5.3.1. A gift is considered any material or non-material value provided or received by an employee or partner of the Company in connection with their professional activities.

5.3.2. Gifts include, but are not limited to:

• Money in any form (cash, checks, certificates, etc.);

• Goods, services, trips, securities, discounts, or discount coupons;

• Payment for entertainment, travel, meals, lodging;

• Other material or non-material benefits that may be perceived as an attempt to influence the decisions or actions of an employee.

5.3.3. Company employees are required to refuse to accept or give gifts that exceed the value established by law or that may be perceived as an attempt to influence their work or decision-making.

5.4. Conflict of Interest:

5.4.1. A conflict of interest arises when an employee’s personal interests may affect the objective performance of their official duties. The Company strives to ensure that conflicts of interest do not adversely affect the interests of the Company or its clients/customers, founders/participants by preventing, detecting, and resolving conflicts of interest.

5.4.2. The Company prevents and resolves conflict of interest situations based on the following principles: 1) mandatory reporting by employees of situations that have signs of a conflict of interest; 2) preventing the occurrence of conflicts of interest; 3) an individual approach to reviewing and assessing each case with signs of a conflict of interest.

5.4.3. Employees are required to report to management any personal, family, or financial interests that may affect their work.

6. Professional Ethics Standards.

6.1. The founders, management, employees, and representatives of the Company, regardless of their positions, during the performance of their official (contractual) duties:

1) strictly adhere to generally recognized ethical norms of behavior;

2) treat with tolerance and respect the political views, ideological, and religious beliefs of others;

3) act regardless of personal interests, personal attitudes towards any individuals, their political, ideological, religious, or other personal views or beliefs;

4) do not disclose or use confidential information that has become known to them in connection with the performance of their official (contractual) duties, except in cases established by law;

5) competently, timely, effectively, and responsibly perform their official (contractual) duties, decisions, and instructions of bodies and officials to whom they are subordinate, accountable, or controlled, and do not allow abuse or inefficient use of the Company's funds and property.

6.2. The founders, management, employees, and representatives of the Company, regardless of their positions, refrain from obviously criminal actions, decisions, and instructions and take measures to cancel such decisions and instructions.

6.3. The founders, management, employees, and representatives of the Company, regardless of their positions, are required to refrain from executing decisions or instructions of the management that are clearly criminal.

6.4. In the event of receiving decisions or instructions that are clearly criminal for execution, the official, employees of the Company, regardless of their positions, and representatives of the Company must immediately report this in writing to the immediate supervisor of the Company.

6.5. The manager, employee of the Company, regardless of their position, cannot be dismissed or forced to resign, disciplined, or subjected to other negative influences or threats of such influences by management due to refusal to execute decisions or instructions that are clearly criminal.

6.6. The manager, employee of the Company, regardless of their position, cannot be disciplined for refusing to participate in corrupt activities, even if such refusal may lead to the loss of the Company's competitive advantage or potential benefit.

7. Procedures for Detecting and Responding to Corruption Offenses

7.1. Reporting Violations: The Company creates conditions for anonymous reporting by employees or other individuals about suspected corruption offenses. Reporting can be done through specially created communication channels specified in the Company's internal regulatory documents.

7.2. Investigation: All reports of possible corruption offenses are subject to impartial review and investigation. The Company ensures the confidentiality of information and the protection of the rights of individuals who report violations.

7.3. Response Measures: In case of detected corruption facts, appropriate disciplinary measures are applied to the guilty individuals, including dismissal, and criminal prosecution may be initiated in accordance with the law.

7.4. Protection of Whistleblowers: The Company guarantees the protection of individuals who report suspicions of corrupt actions, ensuring their confidentiality and protection from reprisals.

8. Interaction with Government Agencies and External Partners

8.1. The Company cooperates with law enforcement agencies, anticorruption institutions, and other organizations engaged in anticorruption activities.

8.2. The Company seeks to cooperate with business partners who conduct their activities legally and ethically, and interaction with whom does not pose corruption risks for the Company.

8.3. The Company informs business partners before establishing business relations with them about the Company's principles and requirements in the field of preventing and combating corruption, as provided by this Policy, including the procedure for checking business partners.

8.4. The verification of the Company's business partners is carried out to:

1) verify the business partner's reputation regarding tolerance to corruption, i.e., whether the business partner has a reputation as an entity whose activities are associated with corruption (even in the absence of relevant court decisions), and whether the business partner will act as an intermediary for transferring unlawful benefits to third parties (or receiving them from third parties);

2) verify the existence of the business partner's anticorruption program (or other anticorruption policies), the status of its actual implementation, readiness (or refusal) to comply with the Company's principles and requirements, as well as anticorruption legislation;

3) identify possible corruption risks associated with the conclusion (execution) of the transaction;

4) minimize the likelihood of committing or verifying possible facts of committing a corruption or related offense, another violation of anticorruption legislation during the establishment and/or implementation of legal relations with a business partner.

8.5. In case of reasonable doubts about the business partner's reputation, which may lead to corruption risks for the Company, the Company reserves the right to refuse the business partner in establishing/continuing business relations, taking into account the requirements of the law.

8.6. The contracts that the Company concludes with business partners may include anticorruption clauses. The purpose of the anticorruption clause is for the Company to provide guarantees of compliance with the applicable anticorruption legislation and to obtain similar guarantees from the business partner.

8.7. Prohibition on Financing Political Parties: The Company prohibits the use of its resources for financing political parties, election campaigns, or any political activities that may be perceived as corrupt.

8.8. The Company may engage in charitable and sponsorship activities in the absence of prohibitions established by law and the Company's internal documents.

9. Control over Policy Compliance

9.1. The responsibility for implementing and ensuring compliance with this Policy rests with the Company's management and a specifically appointed official.

9.2. The Policy is reviewed regularly and may be amended or supplemented to enhance its effectiveness.

9.3. External Audits: The Company allows for the possibility of independent external audits to verify compliance with the anti-corruption policy.
9.4. Periodic Training: The Company is committed to regularly conducting training sessions for employees on the provisions of this Policy and ensuring their awareness of current legislative and regulatory requirements.
9.5. Monitoring and Control Mechanisms: The Company implements procedures for regular monitoring and control of compliance with the anti-corruption policy, including internal audits and risk assessments.

10. Responsibility for Violations of the Policy

10.1. Disciplinary measures in accordance with the law, the Company’s internal labor regulations, and employment agreements shall be applied to employees of the Company who violate the provisions of this Policy.

Contact information:
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to
main@grp-research.com