Anti-Corruption Policy of Law Firm "Gorodissky & Partners"

The laws of many countries provide that the payment or offer of payment or receipt of a bribe, kickback or other corrupt payment is a crime. Russia has a "Law on Combatting Corruption" of December 22, 2008. According to the law, corruption is abuse of one's official position, payment or receipt of a bribe or unlawful use by the person of his/her official status for the purpose of obtaining advantages in the form of money, valuables, other property or services or proprietary rights.

The purpose of this Policy is to ensure compliance by all employees and officers of the Law Firm Gorodissky & Partners (hereinafter referred to as the "G&P") and its branches and affiliates, with the "Law on Combatting Corruption" and related anti-corruption laws of other countries from which G&P receives orders to provide IP services.

In keeping with those laws, G&P prohibits authorizing, offering, giving or promising anything of value directly or indirectly to a government official to influence official action or to anyone to induce them to perform their work duties disloyally or otherwise improperly.

G&P is committed to compliance with anti-corruption laws worldwide. In order to fulfill that commitment, the Company has adopted policies that apply to Company employees, its contractors and business partners. This document describes G&P's policy.

In particular, G&P abides by the rules as follow:

G&P abides by all applicable anti-corruption laws and does not authorize, offer, give or promise anything of value directly or indirectly (through an agent, subcontractor or other intermediary) to a government official in order to influence an official action or to anyone to influence that person to act in breach of a duty of good faith, impartiality or trust ("acting improperly"), to reward the person for acting improperly, or in circumstances where the recipient would be acting improperly by receiving the thing of value. This could include gifts, travel, entertainment, meals or other things of value. Consistent with applicable laws, G&P defines the term "government official" very broadly to include: (1) anyone employed by or acting on behalf of a government, government-controlled entity or public international organization; (2) any political party, party official or candidate; (3) any individual who holds or performs the duties of an appointment, office or position created by custom or convention; and (4) any person who holds him/herself out to be the authorized intermediary of a Government Official.

G&P exercises caution in providing gifts, travel, entertainment, meals or anything else of value to government officials or other individuals in a position to take or influence actions favoring the Company or other persons for whose benefit G&P renders services. If something of value is to be provided at all, a legitimate business purpose must always exist, the value and nature must be appropriate to the circumstances, and all local law restrictions on gifts, entertainment, and travel that can be provided to and accepted by government officials or other individuals must be adhered to at all times.

G&P prohibits payment of facilitation payments (payments made to government officials to expedite routine actions). G&P does not make any charitable or political donations on its own behalf or on behalf of its clients.

G&P keeps and maintains accurate and detailed books and financial records that reflect payments made under, and in connection with, the contracts G&P has with the clients and agents.