Corporate Policy LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia

Our engineering company LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia, always abides by the following legal aspects and principles of cooperation with its partners and customers:

The company’s founders and its management keep a strict watch over the way the company as a whole and its staff in particular comply with legal rules and regulations both of the Russian Federation Laws and generally accepted principles and decisions of the global community. Business activity of our engineering company is based on absolute compliance with laws, standards, regulations, avoidance of various illegal actions, duly tax payment, abstention from unfair competition, elimination of irregularities, adherence to the protection of intellectual property rights and use of trademarks, as well as on fair practice of advertising etc. Our company abstains from deals settled as a result of suspicious actions.
LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia shall immediately alert the competent authorities of any display of faulty business. The Russian company LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" has taken up a strong fight against any display of corruption inside the company and supports efforts of the Russian Federation and the global community in fighting against bribery, racketing and tax evasion.
never offer, either directly or indirectly, any valuables or additional compensation to public officers and their representatives, representatives of political parties and nominees for public office or any person acting on behalf of international social agencies, for the purpose of enticing them to take advantage of their official capacity and assist a company in implementing its business activity, deriving any unlawful benefit, or assist a company or any other person otherwise, and shall never take other actions that break the Regulations of the US Foreign corrupt practices act (FCPA) of 1977, as amended, aimed at making it unlawful for all US citizens and organizations to offer bribes to foreign government officials.
Being a private company throughout its activity, LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia, does not have staff members working for or involved in public service and does not establish business relations with such persons or their relatives. The Russian company LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" complies with the requirement not to employ public officers or their immediate family who may, directly or indirectly, boost business development of the company, under any pretense.
never make or charge its affiliated persons or staff members of any illegal payment transactions throughout its business activity for the purpose of bribery, corrupt practice, payment of payoffs and commission or conduct any other illegal or unlawful activities while purchasing and selling the goods. LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" shall always keep accurate and fair accounting records of the information about all payment transactions, made throughout the company’s activity. The company shall verify the regulations of the applicable laws of the country in which business partners of LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" conduct their activity, to set up a correspondence between the laws and our company’s corporate policy.
the Russian private company LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia, is a fully transparent and open company ready to present any tax information and it secures absolute honesty and transparency of any deal implemented by the company. The company supplies equipment and components for end users only. It is almost always an international contract holder. The company makes payments on international deals itself and conducts customs clearance of the goods with obtaining of the customs declaration, showing all the required taxes paid, by its own efforts only. Financial department of LCC "INTECH GmbH"/ ООО "ИНТЕХ ГмбХ", Moscow keeps a strict watch over the correctness of tax payment in compliance with the Russian Federation Laws and does not have any tax debts or overdue debts to its partners.
clarify to the customers international rules and regulations on doing business without any negative display of shady and corruptive nature specified in the Regulation of the US Foreign corrupt practices act of 1977, as amended, aimed at making it unlawful for all US citizens and organizations to offer bribes to foreign government officials (FCPA); make sure that the partners of LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" and their affiliated persons take a close look and catch the meaning, get advice on the questions that arise while studying the related information and oblige themselves to be committed to the corporate policy of LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ"
inform the management of the customers about any attempts of inappropriate business dealing on the part of the customer’s executors. The notification shall be made in oral and written form using communication channels; in case the notification is not possible due to non-working days, then it shall be made in the first business day.
ask customers’ partners and manufacturers, in case of doubts regarding the compliance with the Regulations of US Foreign Corrupt Practices Act (FCPA), to arrange the auditing of the partner’s documentation or that of its affiliated persons, related to the company’s business activities. Examination of the documentation as well as the auditing should be justified and should be carried out in a reasonable time and where appropriate. The partner has the right, at his own convenience, to authorize a third party to carry out the auditing or examine the documentation, in accordance with the present point, to detect the presence or absence of violations.
Immediately upon receipt of the notification cancel agreements and contracts with enterprises, customers or manufacturers and their affiliated persons, in case LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ", Moscow, Russia, becomes aware of the violation of US Foreign Corrupt Practices Act by the organizations or their affiliated persons. In such a case, LCC "INTECH GmbH" / ООО "ИНТЕХ ГмбХ" shall not bear responsibility to the enterprise and shall claim compensation for any expenses, loss and damage incurred by the company due to the cancellation. The cancellation in this case could be done by the company or its affiliated person by means of a written notification to the defaulting party.
disclose information on its business activities, agreements and contracts with the partners, including terms of payment, to affiliated persons of the company and its employees only, as well as to the partner’s employees and other persons who may require such information, in accordance with laws or regulatory legal acts within the territory of the country where business is conducted, or upon demand of public authorities of the countries involved.
shall not disclose confidential information that the partners will provide during the business activity, and protect it. In this case, when transferring such information, the partners shall indicate its confidentiality, which should be confirmed in written form by both parties.

The terms used:

"Affiliated person" in the meaning of the owner (including a participant, a shareholder or another private or legal person who has direct or indirect financial interest), executive manager, director, partner, principal, employee, agent or any other private or legal person who, either directly or indirectly, runs the enterprise, and is under its control, or together with the enterprise controls a third person.

"Additional compensation" in the meaning of payment, payment proposal, acceptance of payment proposal, payment promise or transfer, either directly or indirectly, (through one or several intermediate parties) of money to the public officer or handing over valuables for underestimated price with the purpose of their assistance or acceleration of performing their usual duties.

"Public officer" in the meaning of an employee or an officer of the government, ministry, agency, public authority or international social agencies, political party, candidates for political service or other persons, acting on an official basic on behalf or in the name of the government, ministry, agency, public authority or international social agencies or political parties.

"Illegal payment transactions" in the meaning of payment, payment proposal, acceptance of payment proposal, payment promise or payment transfer, either directly or indirectly, (through one or several intermediate parties) of money to the public officer or handing over valuables to the public officer with the purpose of their influence on making a decision or getting protection from the side of a public officer, government or political parties in case of the purchase or retention of an enterprise in the interest of a certain person or handing it over to this person; to other private or legal persons in case it breaks any applicable laws of the country on the territory of which such transactions are made, or the company’s policy, including the Foreign Corrupt Practices Act (FCPA).

"Confidential information" in the meaning of data about persons, subjects, facts, events, phenomena, processes regardless of the form of its presentation, that represent banking, trade or business secret or any other confidential information protected in compliance with the Russian Federation Laws, as well as regulatory acts and documents on confidential information protection of the Parties.