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Our Commitment to Anti-Corruption & Anti-Bribery

A core focus of MTS’s proactive compliance efforts is ensuring adherence to applicable laws and regulations against bribery and corruption. MTS’s anticorruption practices, guidelines, and business process controls are set forth in the Company’s core compliance policies, which have been approved by the Board of Directors and are regularly reviewed and updated.

Code of Corporate Conduct & Business Ethics

The MTS Code of Corporate Conduct & Business Ethics is a fundamental document that sets out the principles of internal corporate behavior, rules of interaction of MTS employees with customers, business partners, government authorities, and other external stakeholders. All MTS employees are required to comply with the Code and are personally responsible for their actions.

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Policy on Compliance with Anticorruption Legislation

MTS aims to ensure that the Company’s activities are fully in line with all applicable anticorruption laws, including those of Russia, the United States (FCPA), and the United Kingdom (UK Bribery Act). The Company’s Policy on Compliance with Anticorruption Legislation prohibits offering or providing bribes or facilitating inappropriate payments, while also establishing channels to report compliance concerns.

You may raise a concern anonymously regarding anticorruption or other compliance issues via the MTS Unified Compliance Hotline.

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Policy on Managing Conflicts of Interest

MTS-Illustrated-Guide-to-Conflicts-of-Interest.pdfMTS’s Policy on Managing Conflicts of Interest lays out the company’s principles for preventing and managing conflicts of interest in order to guarantee that the decision-making process and business judgement at MTS are not compromised or inappropriately influenced by personal interests.

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Policy on Gifts & Hospitality

MTS’s Policy on Gifts & Hospitality is aimed at safeguarding the company against the risk of misconduct in accepting or making gifts or considerations as a reward or inducement for desired behavior. Everyone who falls under the conditions of the policy shall exercise the utmost care in the sphere of gifts and hospitality, and will be held personally responsible for their actions in business hospitality.

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