APPROVED

Sole Proprietor

Evgeny Alekseevich Golovanov

July “01,” 2026


ANTITRUST POLICY


Mildway Online Store (website: mildway.ru)
1. General Provisions
1.1. This Antitrust 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 complying with the requirements of the antitrust legislation of the Russian Federation.
1.2. The requirements of this Policy are binding on all employees, partners, and contractors of the Entrepreneur.
2. Objectives of the Policy
2.1. The main objectives of this Policy are:
  • compliance with the antitrust laws of the Russian Federation;
  • prevention of violations of antitrust laws;
  • fostering a zero-tolerance attitude toward violations of antitrust laws among employees and business partners;
  • Protection of the entrepreneur's business reputation.
3. Basic Principles
3.1. The Entrepreneur’s activities are based on the following principles:
  • autonomy and independence in decision-making;
  • the economic rationale for the pricing policy;
  • the prohibition on sharing confidential information with competitors;
  • the prohibition of anti-competitive agreements;
  • openness and transparency in business relationships.
4. Prohibitions
4.1. The entrepreneur, its employees, and its counterparties are prohibited from:
4.1.1. Enter into agreements with Competitors that result in or may result in:
  • setting (maintaining) prices;
  • segmentation of the market by geographic area, buyer composition, or seller composition;
  • a reduction or discontinuation of production of a product;
  • refusal to enter into contracts with certain counterparties.
4.1.2. Discuss or exchange with Competitors any information regarding:
  • prices and pricing policy;
  • terms and conditions of sale;
  • costs and profits;
  • sales volumes and inventory levels;
  • marketing and production plans.
4.1.3. Abuse a dominant market position (if the Entrepreneur holds a dominant market position) by:
  • setting monopolistically high or low prices;
  • unjustified refusal to enter into a contract;
  • imposing unfavorable contract terms;
  • creating discriminatory conditions for counterparties.
4.1.4. Engage in acts of unfair competition, including:
  • discrediting competitors (spreading false information);
  • misrepresentation regarding goods and services;
  • inaccurate comparison with competitors;
  • the use of competitors' trademarks or means of individualization without their consent.
5. Rules for Interacting with Counterparties
5.1. When interacting with Counterparties, the following is prohibited:
  • require suppliers to adhere to fixed or minimum resale prices;
  • reach agreements to boycott other suppliers;
  • use suppliers to exchange information with competitors.
5.2. An entrepreneur sets the prices for their goods independently, based on economic rationale and their own interests.
5.3. Contracts with counterparties must not contain terms that restrict competition (such as exclusivity, territorial restrictions, etc.) unless such terms are economically justified and do not violate antitrust laws.
6. Liability
6.1. Violation of the requirements of antitrust law results in:
  • administrative liability (fines);
  • civil liability (compensation for damages);
  • criminal liability (in particularly serious cases).
6.2. Employees and Contractors who violate this Policy shall be held liable in accordance with the applicable laws of the Russian Federation.
6.3. 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.
7. Reports of Violations
7.1. Every employee and contractor is required to report any known violations of antitrust laws.
7.2. Notifications are sent:
  • by email: mail@mildway.ru (marked “Confidential”);
  • by phone: +7 495 741-98-08.
7.3. The entrepreneur guarantees confidentiality and that no retaliatory measures will be taken against individuals who report violations in good faith.
8. Final Provisions
8.1. This Policy takes effect upon its approval and remains in effect indefinitely.
8.2. The business owner reserves the right to unilaterally amend this Policy.
8.3. Familiarization with the Policy is mandatory for all employees and recommended for Contractors.
8.4. The text of the Policy is posted on the official website, mildway.ru, and is freely accessible to the public.

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