ANTICORRUPTION PROGRAM OF “MOTOR SICH AIRLINES”


 ANTICORRUPTION PROGRAM

OF “MOTOR SICH AIRLINES”

Law-abiding policies and transparency in doing business have been the values of OJSS “Motor Sich Airlines”. In support of these principles, Motor Sich has developed the present Program in order to resist corruption and bribery.


Corruption shall mean a misuse of the given authority with a purpose of a personal gain.
Bribery shall mean an act of an offer or a receipt of any gift, a loan, an award or other advantage in the relation of any person, or from, as a stimuli to make any effort, being unfair or demonstrating an abuse of trust. 


1.    PURPOSES 


The present Program pursues the following aims:
•    Start the business practices of Motor Sich Airlines to resist corruption and bribery;
•    Provide its employees the guidelines to act.

2. OBLIGATIONS


•    “Motor Sich Airlines” carries our a policy of intolerance as for bribery and corruption. This policy covers all the business relationship and the operations of Motor Sich Airlines in all the countries, where the Company, its subsidiaries or partners carry out their activities.
•    This policy has been implemented in the present Anticorruption Program, which shall be regularly reviewed in order to account amendments to the legislation, and the requirements related to the reputation, and changes in business environment.
•    Motor Sich Airlines and its employees, agree with the present Program and with a pursuit to law abiding and transparency.
•    The company’s management shall take a responsibility for the implementation of the Program and for the solution of the problems related to the policies and norms. 


3.     DEFINITIONS OF TERMS AND SCOPE OF PROGRAM APPLICATION


3.1. Political and charitable donations, and sponsorship
Finacial or other support to political parties or political campaigns.
Motor Sich Airlines does not take part in payments of political fees. The employees have the right to enjoy their personal freedom to use their private intentions to participate in political or democratical processes.
Public support and donations shall be acceptable both in the kind of natural services, information provisioning, exchange of services, and that of direct financial donations. The managers and the employees shall with due diligence and transparency guarantee that the charitable donations are not used as an evasion of bribery, and they are not of the nature.


3.2.  Facilitation Payments
Facilitation payments are a form of bribery, which is aimed at expediting or relieving the performance of a public official for the duties assigned. Any acceptance or business safety, or other illegal advantages are regularly not the aim or these payments.
Facilitation payments are regularly requierd by the low-level and low-paid public officials. Due to the mentioned payments, the services, which are normally provided for free, make to be available (for example, issuing of a license). Facilitation payments are prohibited in a majority of the countries. Motor Sich Airlines are against the facilitation payments, and it is fighting with them.


3.3. Gifts and Hospitality
Gifts imply giving, for example, flowers, confectionary or wines. Tickets for sports events or theater, which are provided individually, and not being traditional for the given business environment, shall be also treated as gifts.
Hospitality implies invitations for lunches, receptions, sports and other events adopted in the given business environment.
Gifts and hospitality expenses shall be within reasonable limits, being not too expensive.
Regarding the authorities, hospitality costs and gifts shall be provided within the legislation of the country, being properly fitted to the state officials.
Hospitality expenses and gifts, which can be considered as too expensive or affecting decision-making, shall be unacceptable.


3.4. Protection Money
In certain countries there is a so called “protection phenomena”. This is a form of extortion, which can be associated with physical threats.
Motor Sich Airlines does not pay protection money. Nevertheless, it is responsible before the employees and its business partners, and such cases shall be immediately reported to the management. In certain situations this factor can lead to cancelling business activities.


4.    IMPLEMENTATION


4.1.     Roles and Responsibilities
The duties of every employee shall include a resistance to bribery and corruption in Motor Sich Airlines by observing the present Program.
Every manager and an employee shall have an individual responsibility to guarantee, that the cooperation with state officials is in compliance with all the tolerable legislation and provisions, as well as with the present Program.
Every manager is resposible for the reporting on the present Program and for the awareness of the Program (and all related measures) by all the employees including external staff acting on behalf of Motor Sich Airlines within the limits of their duties.
Chapter 3 of the present Program sets minimal requirements for political, charitable donations and sponsorship, assistance payments, gifts and hospitality limits. They shall not replace state legislation, therefore, in any situation one has to abide the effective legal acts and standards.
In case of a demand for an assistance payment, excessive gifts or hospitality expenses, one shall actively resist to these demands, and to take the following steps:
-    Report (if you have an opportunity) to your manager on the demands before making any payments;
-    Cut any amounts to a minima;
-    Register the information on the payment.

4.1.    Business Partnership
4.1.1.    Subsiduaries and business partners
Before establishing partnerships, Motor Sich Airlines shall act with a corresponding discretion and it guarantees, that the subsidiaries and business partners are aware of the Program of resisting to bribery and corruption, and they respect the Program (they observe the due diligence system).
4.1.2.    Distributors and agents
Commissions to be paid to distributors and agents, shall be adequate and justified awards for legally provided services. The relationships shall be documented, and an agent or a distributor shall contractually confirm his/her agreement to observe the Program. Motor Sich Airlines reserves the right to terminate any agreement in case, if an agent offers or demands a bribe, or by any other means breaches the provisions of the present Program or legislation.
4.1.3.  Subcontractors and suppliers
Motor Sich Airlines carries out the services fairly and transparently, and, when evaluating possible big subcontractors and suppliers, the company performs with a due diligence. Motor Sich Airlines notifies its subcontractors and suppliers on our policy to fight bribery. We reserve the right to terminate any agreement in case, if our subcontractor or a supplier offers or demands a bribe, or by other means, breaches the provisions of the Program or legislation.
Motor Sich Airlines shall avoid of such subcontractors and suppliers, which are known to give bribes.


4.2.   Communication and training
Motor Sich Airlines guarantees that all its employees have been instructed on the present Program, and that they understand it. Every employee shall have a corresponding training, and new ones are to be initially familiar with the Program. Annual compulsory training shall be provided minimally to the key position employees. Training shall include instructions on their activities compliance with the norms and standards of the conduct.  

4.1.     Measures
Motor Sich Airlines has taken a number of measures directed to support the present Program. They include reporting and control (due diligence ones).


4.2.    Sanctions
No employee shall be fined or subjected to any other punishement for a refusal to give a bribe, even if, in the result of his/her actions, Motor Sich Airlines will loose its business.

Any breach of the present Program can be a reason for a disciplinable action and a follow-up dismissal.