APPROVED

Sole Proprietor

Evgeny Alekseevich Golovanov

July “01,” 2026


CODE OF BUSINESS ETHICS


Mildway Online Store (website: mildway.ru)
1. General Provisions
1.1. This Code of Business Ethics (hereinafter referred to as the “Code”) establishes the fundamental principles and standards of conduct for employees, partners, and counterparties of Sole Proprietor Evgeny Alekseevich Golovanov (TIN 362103080174, OGRNIP 326508100307513), hereinafter referred to as the “Entrepreneur.”
1.2. The requirements of the Code are binding on all employees, representatives, and business partners of the Company in the conduct of business.
1.3. The Code cannot address every situation. In case of doubt, an employee or a Counterparty must contact the Business Owner for clarification.
2. Principles of Business Ethics
2.1. The Entrepreneur’s activities are based on the following principles:
  • Honesty and integrity in our relationships with customers, partners, and employees;
  • compliance with the laws of the Russian Federation;
  • respect for customers, partners, and their interests;
  • the prohibition of discrimination on any grounds;
  • the confidentiality of information received in the course of business dealings;
  • the unacceptability of corruption, bribery, and commercial bribery in any form.
3. Customer Relations
3.1. The customer is always the top priority. The business owner and their employees are required to:
  • provide complete and accurate information about the product (composition, properties, instructions for use, precautions);
  • answer customers' questions about the product honestly, without misleading them;
  • Do not push products and services that do not meet the customer's needs.
3.2. The merchant guarantees that all information about the product (including its composition, instructions, and restrictions) is posted on the Website and on the product label. The customer is required to review this information before use.
4. Relationships with Business Partners and Suppliers
4.1. The entrepreneur selects business partners and suppliers based on the principles of fair competition, transparency, and good faith.
4.2. Relationships with counterparties are based on executed contracts and obligations. The entrepreneur and his or her employees are not entitled to demand any personal benefits, gifts, or other valuables from counterparties.
4.3. The Entrepreneur reserves the right to refuse to cooperate with the Counterparty if, during the review, evidence of dishonesty or corrupt activity is uncovered.
5. Confidentiality and Trade Secrets
5.1. Employees and Contractors are required to maintain the confidentiality of information received in the course of their collaboration, including:
  • personal data of customers and employees;
  • commercial information regarding prices, delivery terms, and procurement;
  • information about partners and suppliers.
5.2. It is prohibited to disclose confidential information to third parties, to use it for personal purposes, or in a manner that is detrimental to the Entrepreneur’s interests.
5.3. The obligation to maintain confidentiality applies both during the term of the collaboration and after its termination.
6. Conflict of Interest
6.1. An employee must avoid situations in which his or her personal interests may conflict with those of the Employer.
6.2. An employee must immediately report any potential conflict of interest (for example, if he or she has a personal relationship with a Counterparty, is involved in the selection of a supplier, or holds a stake in a Counterparty company).
6.3. An employee may not use his or her position to gain personal benefit (for example, by demanding gifts from counterparties or making decisions that favor “his or her” companies).
7. Combating Corruption
7.1. The entrepreneur and his employees strictly comply with the requirements of the Federal Law “On Combating Corruption” and adhere to a zero-tolerance policy toward corruption in any form.
7.2. The following are prohibited:
  • give, promise, or offer bribes to public officials, contractors, or their representatives;
  • accept bribes or other valuables in exchange for making decisions in someone's interest;
  • engage in commercial bribery (giving or receiving compensation for actions taken on behalf of third parties).
7.3. It is prohibited to give or receive expensive gifts (worth more than 3,000 rubles) or cash from or to Counterparties. Only souvenirs bearing the Entrepreneur’s logo or small business gifts are permitted.
7.4. If there is any doubt regarding the permissibility of any actions, the employee must consult the Employer.
8. Gifts and Business Etiquette
8.1. It is permissible to receive and give business gifts and souvenirs (calendars, pens, notepads, souvenirs bearing company logos) to counterparties with a total value of no more than 3,000 rubles.
8.2. It is prohibited to receive or provide:
  • funds (cash, gift cards, gift certificates);
  • expensive gifts (over 3,000 rubles);
  • payment for entertainment, travel, and lodging.
8.3. Gifts that exceed the established limit must be returned or turned in, and a written record must be made.
9. Business Communication
9.1. Employees are required to:
  • conduct business correspondence in a respectful and professional manner;
  • respond to requests from customers and counterparties within a reasonable time frame;
  • Do not tolerate insults, threats, or psychological pressure;
  • Follow the etiquette of telephone conversations.
9.2. When interacting with clients, business partners, and colleagues, employees must adhere to high standards of courtesy and professionalism.
10. Assets and Resources
10.1. Employees are required to treat the Employer’s property with care and to use it exclusively for work purposes.
10.2. Resources (including equipment, supplies, and communication tools) may not be used for personal purposes unless otherwise specified in the employment contract.
11. Liability
11.1. A violation of the provisions of this Code constitutes grounds for disciplinary action, including termination of the employment contract.
11.2. The Entrepreneur has the right to unilaterally terminate the contract with the Counterparty in the event that the Counterparty violates the provisions of the Code.
11.3. If violations are discovered that appear to constitute a crime, the Business Owner has the right to contact law enforcement authorities.
12. Reports of Violations
12.1. Every employee and contractor is required to report any known instances of corruption, conflicts of interest, or other violations of the Code.
12.2. Notifications are sent:
  • by email: mail@mildway.ru (marked “Confidential”);
  • by phone: +7 495 741-98-08.
12.3. The entrepreneur guarantees confidentiality and that no retaliatory measures will be taken against individuals who report violations in good faith.
13. Final Provisions
13.1. This Code shall enter into force upon its approval and shall remain in effect indefinitely.
13.2. The business owner reserves the right to unilaterally amend the Code.
13.3. Familiarization with the Code is mandatory for all employees and recommended for business partners.
13.4. The text of the Code is available to the public on the official website, mildway.ru.

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