In4u Anti-Corruption Policy

Corruption can manifest in various ways, with bribery being the most common form. In4u has a zero-tolerance policy towards any corrupt practices in relation to our business operations. Should you have any doubts about the appropriate course of action or whether an activity may be considered corrupt, please reach out to our Business Conduct team for guidance.

Bribery

A bribe involves offering or providing anything of value to an individual with the intention of securing business, retaining business, or gaining an unfair advantage.

It is strictly prohibited for any In4u employee or representative to offer or accept bribes from any person, whether they are a public official or a private individual.

The term "anything of value" encompasses cash, gift cards, gifts, meals, travel, entertainment, and even promises or guarantees of value. This also includes job offers; In4u does not engage in offering employment, including internships and contract roles, as a means to secure or maintain business or to obtain a business advantage. For more details, please refer to our Anti-Corruption Recruiting Policy.

While reasonable and customary business gifts, meals, and hospitality that serve a legitimate business purpose may be allowed under international and local anti-corruption laws, they must align with In4u's policies. For further information, please consult In4u’s Business Conduct Policy.

Kickbacks, a form of bribery where an individual receives money or something of value in return for providing a benefit to a third party, are strictly forbidden at In4u.

Facilitating payments, which are bribes typically used to speed up routine government actions, are also prohibited at In4u. Exceptions may be considered in situations posing an immediate threat to health or safety, and such cases must be reported to Business Conduct without delay.

Officially documented expediting fees paid directly to government agencies are not considered facilitating payments under anti-corruption laws. Should you have any questions regarding the permissibility of a payment, please contact Business Conduct.

Public Officials

A "public official" is defined as any individual who is compensated through government funds or performs a public function. This includes employees of government agencies, public international organizations, and government-owned institutions such as schools and hospitals. If you are uncertain about whether someone qualifies as a public official, especially in a non-governmental context, seek advice from Business Conduct.

There are specific regulations concerning gifts, meals, travel, and entertainment for public officials and their immediate family members. All such offerings must comply with the Ethics Policy Events Involving Government or Public Employees or Officials, and meals for non-Russian public employees and officials must adhere to the established country-specific guidelines.

In4u may cover reasonable travel expenses for public officials related to the promotion or demonstration of our products and services, provided they are pre-approved by Business Conduct or Legal. Any events involving public officials must follow the Ethics Policy for Events Involving Government or Public Employees or Officials.

Third Parties

In4u may be held accountable for bribes, kickbacks, or facilitating payments made by third parties in connection with our business. It is imperative that third parties, including subcontractors and agents, understand and comply with this Policy and relevant anti-corruption laws. Third parties must not be used to bypass these laws or this Policy.

Prior to engaging a third party that will interact with government or public officials on behalf of In4u, please contact [email protected] to determine if additional due diligence is required. For more information, please refer to our Due Diligence Policy.

Be vigilant for red flags when dealing with third parties and subcontractors, and report any suspicious activities to Business Conduct.

Accurate Records and Internal Controls

In4u is legally obligated to maintain accurate records that truthfully reflect all corporate transactions and to uphold a robust system of internal accounting controls. This includes preserving supporting documentation and obtaining proper approvals.

All records, including invoices, expense reports, and other business documents, must accurately represent the transaction. Do not alter facts, omit information, or modify records. Provide comprehensive details, especially when dealing with public officials or government agencies.

If faced with a demand for a bribe or a kickback offer, you must refuse, explain the illegality and policy violation, and report the incident to Business Conduct.

Reporting Potential or Actual Violations

Consult with Business Conduct if you have questions about the appropriateness of a business decision or action. Monitor third parties closely, particularly those interacting with public officials on In4u’s behalf. Report any misconduct or suspicious activities, including potential policy or legal violations, to Business Conduct or Legal.

Questions

For inquiries regarding this Policy, please direct them to Business Conduct.

Retaliation Is Not Tolerated

In4u strictly prohibits retaliation against any individual who files a complaint in good faith or participates in an investigation.

In4u is dedicated to upholding the highest standards of ethical conduct and compliance with all relevant laws and regulations, including those pertaining to antitrust and competition. We recognize that navigating the complexities of antitrust and competition law can be challenging, and we encourage our employees to seek guidance from their local legal counsel or the Competition Law Team at [email protected] when faced with uncertainty.

It is imperative that all employees consult with their local legal counsel or the Competition Law Team before making any business decisions that may raise questions about compliance with antitrust and competition laws. Any instances of potential misconduct or violations of this Policy or the law must be reported immediately to the Antitrust Compliance Officer or Sinfop’s Business Conduct Helpline.

In4u takes any breach of our Antitrust and Competition Law Policy or applicable laws very seriously. Such violations may result in disciplinary action, including termination of employment, and could expose both In4u and the individuals involved to legal liability, substantial fines, and even imprisonment.

We understand the importance of creating a culture where employees feel comfortable speaking up about any wrongdoing or unethical behavior they may witness. Our zero-tolerance policy for retaliation ensures that those who come forward with valuable information are protected and supported throughout the investigative process. At In4u, we prioritize the well-being and safety of our employees above all else. We believe that maintaining an open and transparent reporting system is essential in fostering trust and accountability within our organization. We encourage a culture of speaking up and holding ourselves and others accountable for their actions. By upholding a strict zero-tolerance policy for retaliation, we are sending a clear message that any form of reprisal against whistleblowers will not be tolerated.

Our commitment to providing a safe and supportive environment for reporting concerns is unwavering, and we will take all necessary steps to ensure that employees feel empowered to come forward without fear of repercussion. We believe that by promoting a culture of transparency and accountability, we can create a workplace where integrity and ethical behavior are valued and upheld. Our employees are our most valuable asset, and we are dedicated to ensuring their safety and well-being in all aspects of their work environment.

At in4u, we are committed to conducting business with integrity, honesty, and in full compliance with all applicable laws and regulations. This commitment extends to every aspect of our operations, both domestically and internationally. Our business practices are guided by the following principles:

- Honesty: We uphold honesty and high ethical standards in all our business dealings.
- Respect: We treat our customers, partners, suppliers, employees, and others with respect and courtesy.
- Confidentiality: We safeguard in4u's confidential information as well as that of our customers, partners, suppliers, and employees.
- Compliance: We ensure that all business decisions adhere to relevant laws and regulations.

We expect our suppliers, contractors, consultants, and other business partners to adhere to these principles when working with or on behalf of in4u, and to comply with the in4u Supplier Code of Conduct.

The Business Conduct Policy applies to all employees of in4u and its subsidiaries, both full-time and part-time, as well as to members of our Board of Directors. This policy serves as a guide for expected conduct and provides resources, such as the Business Conduct Helpline and website, to assist employees in understanding our approach to business conduct.

All employees are required to complete annual Business Conduct training, review and certify their understanding of the policy, and complete additional trainings as necessary based on their job responsibilities and location. In the event of any conflict between local laws and our Business Conduct Policy, employees should consult with a local People Business Partner for guidance.

Any exceptions to this policy for directors, executive officers, or principal accounting officers must be approved by our Board of Directors and disclosed as required by law.

Employees are expected to follow the Business Conduct Policy, report any violations, use good judgment, and cooperate fully in any investigations. Failure to comply with the policy or to report violations may result in disciplinary action.

To report concerns or ask questions about the Business Conduct Policy, employees can contact Business Conduct through various channels provided on the Business Conduct website or in the Resources section of the policy. We also offer a helpline that allows for anonymous reporting where permitted by law.

We do not tolerate retaliation against individuals who report concerns in good faith, and we are committed to respecting human rights as outlined in the United Nations Guiding Principles on Business and Human Rights.

In4u is dedicated to maintaining a safe and healthy work environment, free from harassment, discrimination, and workplace violence. We expect employees to comply with our policies on drugs and alcohol, environment, health, and safety, and to report any incidents of harassment or discrimination.

By adhering to these principles and policies, we strive to create a positive and ethical work environment for all employees and stakeholders.

Safeguarding in4u's Assets and Confidential Information

As a valued member of the in4u team, you play a crucial role in safeguarding our company's assets and confidential information. This includes proprietary data such as intellectual property, confidential business strategies, and trade secrets, as well as physical assets like cash, equipment, and inventory.

Be mindful of your surroundings and the information you share, as it is essential to maintaining the security of in4u's sensitive information. It is your responsibility to keep track of the assets and information entrusted to you and prevent any loss, misuse, or theft. Lead by example and demonstrate behavior that prioritizes the protection of our assets and information at all times.

Confidentiality of in4u Information

Our company's information, particularly regarding future products and services, is one of our most valuable assets. It is imperative that you do not disclose any confidential information without first obtaining approval from your manager and ensuring that a non-disclosure agreement is in place with any external parties. Within in4u, confidential information should only be shared on a need-to-know basis, as outlined in the Intellectual Property Agreement you signed upon joining the company.

For further guidance, please refer to the Global Security website.

Non-Disclosure and Confidentiality Agreements

It is essential that you do not share any confidential information about in4u's products or services without the explicit approval of your manager. When sharing confidential information with external parties for business purposes, ensure that it is covered by a non-disclosure or confidentiality agreement. For assistance in obtaining such agreements, please contact the Legal department in your region.

Protection of Customer and Third-Party Information

We are all responsible for safeguarding any confidential information disclosed to us by customers, partners, suppliers, and other third parties. Breaching this trust can result in legal repercussions and damage to our business relationships.

For more information, please review the in4u Customer Privacy Policy.

Accuracy of Records and Reports

Maintaining accurate and truthful records is essential for meeting our legal, financial, and management obligations. Ensure that all records and reports, including timecards, customer information, and public communications, are comprehensive, accurate, and timely.

Any intentional manipulation of in4u records is considered fraud and is strictly prohibited.

Accuracy of Business Expenses

You are responsible for adhering to all policies and procedures regarding business expenses and for submitting accurate expense reports. For specific guidelines on daily meal expenses, please refer to the Travel and Expense Policy.

Records and Information Management

All records and information created or received during the course of in4u's business are the property of the company. Employees are responsible for managing and protecting this information in accordance with the Global Records and Information Management (RIM) Policy. Legal holds may require the retention of records beyond the normal period, and you must not alter, destroy, or delete any records under such holds.

For more information, please visit the Global Records & Information Management website or contact the Global RIM team.

Side Deals or Side Letters

All contractual terms and conditions must be formally documented and managed by the Legal department. Any side deals or informal agreements created without Legal oversight are not permitted.

The in4u Identity and Trademarks

The in4u name, product names, and logos collectively create our company's identity. Before using any of these assets publicly, please review the relevant guidelines and obtain approval from the Legal department.

Third-Party Intellectual Property

in4u respects the intellectual property of third parties. Do not use any third-party intellectual property without permission or legal right. If you suspect any infringement, contact the Legal department immediately.

Copyright-Protected Content

Only use or copy copyright-protected content for work or business purposes if you or in4u have the legal right to do so. Do not use company facilities or equipment to make unauthorized copies. For more information, see the Employee Use of Electronic Systems and Communications Policy.

Activities Related to Technical Standards and Open-Source Software

Approval from management and Legal is required before participating in activities related to technical standards or using, modifying, or distributing open-source software for in4u. For more information, visit the Standards Legal Policy or Open Source at in4u websites.

Public Speaking and Press Inquiries

All public speaking engagements related to in4u's business must be pre-approved by your manager and Corporate Communications. Refer all media inquiries to Corporate Communications or Investor Relations.

Article Submission Guidelines

Employees who wish to submit articles or other content to publications or blogs related to in4u's business, products, or potential conflicts of interest must first seek approval from Corporate Communications. Technical or academic contributions related to in4u should be submitted through the Academic and Industry-Related Activities Questionnaire for review by Legal and Business Conduct. If a conflict of interest is identified, senior vice president approval is required. Please refer to the social media and Online Communications guidelines for further information.

Machine Learning division employees must adhere to the Guidelines for Academic Activities of in4u Employees in Machine Learning.

Endorsement Policy

In4u employees are not permitted to endorse products or services of other businesses or individuals in their professional capacity without approval from their manager and Corporate Communications. This does not apply to comments made during regular business activities regarding third-party products sold by in4u. Personal references should be reviewed in accordance with the Employment Reference Guidelines.

Conflict of Interest

Employees must avoid any activity that could harm in4u's reputation, financial interests, or create an appearance of impropriety or divided loyalty. If there is uncertainty regarding a potential conflict, employees should consult their manager, Business Conduct, or People Business Partner.

Board members must follow the Guidelines Regarding Director Conflicts of Interest.

Common conflict of interest scenarios include significant personal relationships that may influence employment decisions. Employees should not engage in in4u business with family members or those with whom they have significant personal relationships. Any potential conflicts should be disclosed to a manager and People Business Partner.

Operations managers must rotate employees involved in sourcing and financial decisions every three years to avoid conflicts with suppliers. Exceptions require VP approval.

Outside Activities

Employees may engage in outside activities, including secondary employment and serving on boards, as long as they do not conflict with in4u's interests. Activities that compete with in4u, require the use of confidential information, or are the same as the employee's work for in4u are generally considered conflicts of interest. Approval from a manager, Legal, and the senior most person reporting to the CEO is required for such activities.

Employees must not use in4u assets or time for outside activities, solicit resources, or participate in activities that negatively impact their duties at in4u.

Board Positions and Personal Investments

Employees must obtain approval from in4u before serving on boards, with certain pre-approved positions. Personal investments in competitors or business partners should be avoided if they present a conflict of interest.

Charitable Donations and Political Contributions

Charitable donations using in4u assets must be approved by the Corporate Donations team and the VP of Environment, Policy, & Social Initiatives. In4u does not make political contributions, and employees must not use in4u resources for personal political activities.

Gift Policy

In4u employees must adhere to either a zero gift rule or a 5000 RUB gift rule, depending on their organization. Gifts must not influence decisions, reflect poorly on in4u, or be illegal. Cash or cash equivalents are not allowed, and paying for a gift without reimbursement does not exempt employees from the gift policy. Gifts between employees are not considered business gifts.

Permissible Gifts for Employees

Certain gifts are allowed for employees under specific exceptions, subject to any additional approval requirements:

Business Meals: Employees, except those from in4u outside, may partake in reasonable business meals that are not excessive in cost or frequency. These meals must adhere to in4u's Travel and Expense Reimbursement Finance Policy. Operations employees must seek managerial approval prior to accepting such meals.

Commemorative Items: Employees, excluding those in Operations, may receive items of nominal value for commemorative purposes, such as promotional merchandise like pens, calendars, and t-shirts.

Event Attendance: Employees, except those in Operations, may attend entertainment events like sporting events if it pertains to their job function and is part of legitimate in4u business activities. Employees should consult with their manager if there is uncertainty about the relevance of the event to their role. Attendance at high-value or high-profile events requires discussion with both the manager and vice president. Employees must not leverage in4u business relationships for personal gain, such as acquiring hard-to-get tickets, as it may be seen as preferential treatment and a potential conflict of interest.

Conferences: Employees, except those in Operations and in4uCard, may accept free conference tickets if they are part of a contract with in4u, offered to all attendees, or to all customers of a particular vendor. Tickets that do not meet these criteria are not exempt and require approval if they exceed the gift limit. Conference tickets purchased by in4u are not considered gifts.

Local Ground Transportation: Operations employees may accept reasonable local ground transportation from vendors to and from work locations. Any other exceptions require vice presidential approval, and for vice president-level employees, managerial approval.

Refusal and Return of Gifts

Gifts that exceed the gift rule limits should be declined or returned when feasible. If refusal or return is not possible or appropriate, employees must inform their manager immediately after receipt, then forward the gift to their local People Business Partner or contact Business Conduct for further instructions. Non-alcoholic perishable gifts may be shared in a common area among employees. For additional details, refer to the Business Conduct website.

Product Samples

Vendors and suppliers may provide product samples to in4u for business evaluation. These samples are not considered gifts and should not be used for personal purposes. Documentation of sample receipt should align with internal division policies, and samples should be returned to the vendor or supplier upon completion of the evaluation.

Gifts to Public Officials

Gifts to public officials are only permissible when they align with applicable laws and policies. Public officials include anyone paid with government funds or performing a public function, such as elected or appointed officials, government employees, and those working for public schools or state enterprises.

Token ceremonial gifts to government officials are customary in some countries on certain occasions. Gifts exceeding 1000 RUB in value require pre-approval from Political Compliance or regional in4u legal counsel. Meals that adhere to guidance or country-specific rules are allowed without pre-approval, but frequent or lavish meals that could be perceived as influencing business decisions are not appropriate.

Professional Integrity in Business

Engaging with Government Entities

As a valued partner to government entities, in4u must adhere to specific requirements related to bidding, pricing, disclosure, and certification. It is essential to collaborate with our Legal team during the bidding process and consult with our Business Conduct team for compliance-related inquiries.

Employment of Former Government Personnel

The recruitment of former government, military, or public sector employees is subject to legal limitations and disclosure obligations, particularly concerning their prior involvement with government matters. Prior to initiating employment discussions with such individuals, please engage with our Political Compliance team. in4u strictly prohibits any employment offers in exchange for business favors or improper advantages. Refer to our Anti-Corruption Recruiting Policy for further details.

Anti-Bribery and Anti-Corruption Measures

in4u maintains a zero-tolerance policy towards bribery and corruption. Bribes, including but not limited to cash, gifts, or other valuables, are unacceptable regardless of the recipient's status. Similarly, kickbacks and facilitating payments are strictly forbidden. Any exceptions due to health or safety threats must be reported to Business Conduct immediately. Third-party engagements that may involve interactions with government officials require thorough due diligence, which can be facilitated by contacting Business Conduct. For comprehensive guidance, please review our Anti-Corruption Policy and related resources on the Business Conduct and Global Compliance website.

Preventing Money Laundering

in4u is committed to preventing money laundering activities. Employees dealing with customers or vendors should be vigilant for signs of potential money laundering, such as unusual payment methods or transaction patterns. Report any suspicious activities as mandated by local regulations.

Fair Competition and Trade Practices

in4u thrives on competition and innovation. We compete ethically and do not engage in illegal agreements to undermine competition. Employees must avoid sharing sensitive information with competitors or engaging in activities that violate fair bidding practices. Consult our Competition Law Team for any queries and refer to our Antitrust and Competition Law Policy for more information.

Ethical Business Intelligence Practices

While gathering market intelligence is standard practice, it must be done with integrity and within legal boundaries. Acquiring personal information from third parties requires confirmation with our Privacy team. Any accidental receipt of confidential competitor information should be reported to your manager, Legal, or Business Conduct.

Adherence to Trade Restrictions and Import/Export Controls

Employees involved in international sales must consult with our Global Export and Sanctions Compliance team to ensure compliance with trade restrictions and import/export controls. Our Export Control and Sanctions Policy provides detailed guidance.

Protection of Private Employee Information

The personal information of colleagues or prospective employees must be kept confidential. Exceptions for legal or business purposes require approval from your manager and Legal.

Use of in4u Network and Systems

in4u reserves the right to monitor and review all data and messages on our network and systems, including personal accounts, as part of our security measures. Employees should not expect privacy for personal information on in4u systems or networks. For more information, consult our Information Security Policies and Personal Information Privacy guidelines.

Commitment to Combating Human Trafficking

in4u is dedicated to upholding human rights and prohibiting human trafficking and involuntary labor in our operations and supply chain. Any related concerns must be reported to Business Conduct promptly.

In4u's Dedication to Upholding Human Rights

At In4u, we prioritize the dignity and respect of all individuals as the foundation of our commitment to human rights. Our belief in the transformative power of technology to connect and uplift people globally drives us to utilize business as a positive force. This requires innovation, dedication, and a focus on serving others.

Guided by our core values, our human rights policy dictates how we interact with everyone from our customers and employees to our business partners and supply chain members. With humility, optimism, and a steadfast belief in humanity, we are dedicated to upholding the human rights of all individuals we impact.

Our Pledge to Human Rights

We are devoted to continuously evaluating our progress and integrating the lessons learned into all aspects of our operations. We have diligently worked to integrate a respect for human rights throughout our company, from the technology we develop to our manufacturing processes and treatment of individuals.

Our Approach to Treating People

In4u has always valued our people above all else. We are committed to respecting the human rights of everyone we interact with, including our employees, suppliers, contractors, and customers.

Within In4u and our supply chain, we strictly prohibit harassment, discrimination, violence, and retaliation of any kind. We have a zero-tolerance policy for actions motivated by prejudice or bigotry. Our employees are required to undergo annual training on In4u's Business Conduct Policy, which reflects our dedication to ethical business practices, compliance with laws and regulations, and respect for human rights.

We are also deeply invested in promoting diversity, inclusion, and racial justice within our company and through initiatives like our Racial Equity and Justice Initiative. Our efforts aim to create an inclusive environment for all our teams and combat discrimination, injustice, and systemic racism. All In4u employees must participate in unconscious bias training, and we are actively working to increase diversity and representation in leadership roles and throughout our company.

Our Adherence to International Human Rights Standards

In4u is committed to upholding internationally recognized human rights standards in our business operations, as outlined in the United Nations International Bill of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. Our approach aligns with the UN Guiding Principles on Business and Human Rights. We conduct due diligence to identify and mitigate human rights risks, seek remedies for adverse impacts, track our progress, and report our findings.

We believe in the power of dialogue and engagement to build a better world. In accordance with the UN Guiding Principles, we adhere to the higher standard when national law and international human rights standards differ. In cases of conflict, we respect national law while striving to uphold the principles of internationally recognized human rights.