Compliance

Our Company constantly strives to operate in strict compliance with applicable laws and corporate ethics principles which is a guarantee of our impeccable reputation. After Philip Morris International and Japan Tobacco International were included in the shareholding structure of MEGAPOLIS, the Supervisory Board of Megapolis Distribution B.V. resolved to further develop the risk management system in compliance with the best global practice and applicable laws. In furtherance of such strategy, MEGAPOLIS established a Compliance Department that directly reports to the Supervisory Board. Our Company believes that a full-scale development of the compliance and control function is an instrument that will ensure the assurance of shareholders that the Company:

operates in an open and honest manner on the basis of mutual benefit and honest entrepreneurship, intolerance of any displays and types of corruption, bribery or money laundering and in accordance with high ethical standards;
assesses the ethical risks of its business operations, including the verification of all business relations of the Company, as thoroughly as it assesses its commercial risks;
has established policies and procedures that are adequate and proportional to the ethical risks of the Company’s business;
ensures that each employee of the Company knows, understands and strictly complies with the Company’s ethical principles of business, has received the training that would enable him or her to assess with confidence and manage all ethical risks and to notify the Company ‘s management of all potential cases of illegal or unethical conduct;
strives to ensure that all business partners and persons acting on behalf of the Company comply with our Company’s strict ethical business standards.

Code of Conduct

The Supervisory Board of Megapolis Distribution B.V. approved a revised corporate Code of Conduct. The Code summarizes and describes the key principles of MEGAPOLIS’ business and establishes the rules and requirements that shall be followed by the Company’s employees in the course of performance of their functions. The Code also contains a summary of the key policies relating to the Compliance.

Policies Relating to Compliance

The Supervisory Board of Megapolis Distribution B.V. approved the following key policies in the Compliance:

The Anti-Bribery and Corruption Policy;
The Anti-Money Laundering Policy,
The Anti-Illicit Trade Policy,
The Trade Controls Policy,
The Screening, Assignment and Recusal Policy,
The Investigations Committee Policy.

Helрline

The Helpline is an efficient instrument to oppose illegal actions and non-compliance with the ethical rules of business set forth in the Code of Conduct and corporate policies. The Company agrees that the success of MEGAPOLIS directly depends on the confidence of its employees and partners in the Company’s development strategy and principles of business and would appreciate the opinion of each interested person. For such purpose, the Company has arranged a Helpline as a feedback opportunity.

The MEGAPOLIS Compliance Helpline is administered by an external consultant which guarantees an independent processing of reports, confidentiality and anonymity.

If you become aware of:

any potential or actual event of corruption, fraud or misappropriation in the Company;
sales of any falsified or counterfeit products that belong to the product range of MEGAPOLIS;
any event involving a conflict of interests with respect to the Company’s employees;
any abuse of office or misuse of powers by an employee of MEGAPOLIS;
any illegal financial operations within the Company;
any misrepresentation of financial statements and management accounts of MEGAPOLIS;
any event of discrimination in the Company;
any other action or omission that conflicts or would conflict with the principles of business and operation set forth in the Code of Conduct and in the adopted corporate policies,

please report the matter immediately to the MEGAPOLIS Compliance Helpline by any of the following means of communication:

Phone:
8-800-500-2899 (free in Russia)

E-mail:
hotline@gkm.ru

Site:
https://www.gkm.ru/hotline/

The operation of the Helpline is based on three main principles as follows:

Confidentiality and anonymity
NO information will be passed over to your supervisor or colleagues. You will NOT be retaliated by the Company, whatever the nature of your report.

100% of reports will be processed
No report will be ignored and each report will be considered in accordance with the established procedure.

Actions to be taken with respect to each report
In the event of a confirmed non-compliance, MEGAPOLIS will endeavor to take all proper actions and to prevent any event of illegal or unethical conduct. If you provide your contact details, you will be certainly informed of the investigation outcome.