Preventing Fraudulent and Corrupt Practices

The goal of PrJSC “MTS Ukraine” (hereinafter – the Company) is to promote high ethical standards in relations with its suppliers and build mutually beneficial relations on the long-term basis. Supplier relations are based on the principle that all organizations, suppliers of services and goods to the Company, contractors and consultants partaking in the procurement process shall comply with the highest ethical standards while interacting with the Company (including in the procurement process).

The Company establishes the following rules for all stages of the procurement process:

All procurement procedures of the Company shall be performed on public and transparent basis in compliance with all requirements of local legislation, and applicable international law. The Company is a component of OJSC “Mobile TeleSystems” (NYSE: MBT), “Mobile TeleSystems” is listed on New York Stock Exchange and should meet the requirements of the Sarbanes-Oxley Act.
Corrupt Practice means the actions aimed at offering, receiving, giving, or soliciting, directly or indirectly, a financial or other benefit to influence improperly the actions of another party.
Fraudulent practice means any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.

PrJSC “MTS Ukraine” shall be entitled to reject a Proposal, if it has found that the Bidder has been involved in corrupt or fraudulent practice at any stage of the Request for Proposals; and the Company also shall be entitled to immediately cancel the Contract made with the Winning Bidder, based on the results of the Request for Proposals, by sending a written notice signed by the General Director of PrJSC “MTS Ukraine”, in the event that during the contract period it is found that the Winning Bidder has been involved in fraudulent or corrupt practices.

The Company shall be entitled to reject the Proposals of the Bidders who have made any arrangements among each other aimed at influencing improperly the selection of the Winner of the Request for Proposals process.

The Company reserves the right to declare the Bidder to be a party deprived of the right to take part in any further relations with the Company for definite or indefinite time if it is revealed that this Bidder has been involved in corrupt or fraudulent practices either at the time of Request for Proposals or later or in the event that the same Bidder or its officials have been reported by governmental agencies to be implicated in the same practices.

If a Bidder has any grounds to believe that any decision of any Request for Proposals process was nontransparent or the same decision does not benefit the Company to the maximum extent, the same Bidder may inform of the same facts confidentially to the Company’s hot-line in accordance with the Illegal Action Prevention Policy. A communication will be reviewed under the Internal Audit Team Leader’s coordination and the investigation findings will be reported both to the Bidder and the Company’s top managers.

To leave a communication, the Bidder may use any e-mail box at any public e-mail server from an Internet-cafй or any other place to keep the sender’s personal details in secret. Please, send your messages to wbp@mts.com.ua There are also other ways to report information and leave messages, see details at: http://company.mts.com.ua/eng/antiswindle_politicy.php

All electronic messages received at wbp@mts.com.ua shall be considered within 2 workdays by the Internal Audit Team Leader who identifies an approximate date for a final decision on each message and communicates the same date to a sender.

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