APPROVED

Sole Proprietor

Evgeny Alekseevich Golovanov

July “01,” 2026

ANTI-CORRUPTION POLICY


Mildway Online Store (website: mildway.ru)
1. General Provisions
1.1. This Anti-Corruption Policy (hereinafter referred to as the “Policy”) is an internal document of Sole Proprietor Evgeny Alekseevich Golovanov (TIN 362103080174, OGRNIP 326508100307513), hereinafter referred to as the “Entrepreneur,” and establishes uniform principles and procedures aimed at preventing and combating corruption in the Entrepreneur’s activities and in his interactions with Counterparties.
1.2. The requirements of this Policy are binding on all employees, partners, and contractors of the Entrepreneur.
2. Terms and Definitions
2.1. Corruption – abuse of official position, giving a bribe, receiving a bribe, commercial bribery, or any other unlawful use by an individual of his or her official position contrary to the legitimate interests of society and the state for the purpose of obtaining benefits in the form of money, valuables, other property, or services of a property nature.
2.2. Bribe– any benefits unlawfully accepted by a public official in exchange for an act (or omission) in the interest of the person providing them.
2.3. Counterparty – a legal entity or sole proprietor with whom a contract for the supply of goods, work, or services has been entered into or may be entered into.
2.4. Values – cash, goods, services, gifts, entertainment events, trips, job offers, and any other material benefits.
3. Principles of Anti-Corruption
3.1. The Entrepreneur’s activities are based on the following principles:
  • the unacceptability of corruption in any form or manifestation;
  • compliance with the laws of the Russian Federation on combating corruption;
  • openness and transparency in business relationships;
  • refusal to cooperate with individuals involved in corrupt activities;
  • The inevitability of liability for violations of this Policy.
4. Prohibition on Bribes and Commercial Bribery
4.1. The entrepreneur, its employees, and its counterparties are prohibited from:
  • give, promise, or offer any valuables to officials of state or municipal agencies;
  • give, promise, or offer any benefits to employees of counterparties for the purpose of obtaining an advantage in the conclusion or performance of contracts;
  • receive benefits from counterparties in exchange for making decisions in their best interests.
4.2. The prohibition applies to both direct and indirect actions (through intermediaries, relatives, or persons under one’s control).
5. Rules of Business Etiquette
5.1. It is permissible to give business gifts and promotional items (calendars, pens, notepads) to counterparties and to receive such items from them, provided that the total value does not exceed 3,000 rubles per occasion.
5.2. It is prohibited to give or receive:
  • cash, gift cards, and gift certificates;
  • expensive gifts (over 3,000 rubles);
  • payment for entertainment, travel, and lodging.
5.3. Any gifts exceeding the established limit must be returned or surrendered, and a written record must be made.
6. Counterparty Due Diligence
6.1. Before entering into a contract with a Counterparty, the Entrepreneur shall conduct a due diligence review of the Counterparty, which includes:
  • verification of registration information (TIN, OGRN, address);
  • checking for any pending litigation or enforcement proceedings;
  • Requesting feedback on a counterparty from partners.
6.2. The Entrepreneur has the right to refuse to cooperate with the Counterparty if, during the review, evidence of corrupt activity or other misconduct is uncovered.
6.3. Contracts with counterparties shall include provisions requiring compliance with the requirements of this Policy.
7. Liability
7.1. Employees and Contractors who violate this Policy shall be held liable in accordance with the applicable laws of the Russian Federation.
7.2. The entrepreneur reserves the right to:
  • impose disciplinary action on an employee, up to and including termination;
  • terminate the contract with the Counterparty unilaterally;
  • contact law enforcement authorities to hold the perpetrators accountable.
8. Reports of Violations
8.1. Every employee and contractor is required to report any instances of corruption or attempts to induce corrupt conduct that come to their attention.
8.2. Notifications are sent:
  • by email: mail@mildway.ru (marked “Confidential”);
  • by phone: +7 495 741-98-08.
8.3. The entrepreneur guarantees confidentiality and that no retaliatory measures will be taken against individuals who report violations in good faith.
9. Record-keeping and Monitoring
9.1. All expenses related to business meetings, negotiations, and hospitality events must be recorded in accounting documents, specifying the purposes and participants.
9.2. Payments that are not supported by documentation or justification are prohibited.
10. Final Provisions
10.1. This Policy takes effect upon its approval and remains in effect indefinitely.
10.2. The business owner reserves the right to unilaterally amend this Policy.
10.3. Familiarization with the Policy is mandatory for all employees and recommended for Contractors.
10.4. The text of the Policy is posted on the official website, mildway.ru, and is freely available to the public.

© 2026 E.A. Golovanov, Sole Proprietor. All rights reserved.