Anti-corruption policy

Compliance is one of the most important elements of the investment company's management system, aimed at protecting the interests of clients, partners, and shareholders, comprising a set of measures to identify, eliminate, and prevent violations of Russian and international legislation, as well as the requirements of self-regulatory organizations and internal documents of "BrokerName" LLC (hereinafter - the Company).

On a daily basis, the Company implements a compliance management program aimed at ensuring the Company's activities comply with legislation, international standards, and best practices in various areas of activity of a professional securities market participant:

·        Anti-Money Laundering and Combating the Financing of Terrorism.

·        Compliance with appropriate standards of market behavior.

·        Management of conflicts of interest.

·        Compliance with ethical standards regarding the organization's personnel and individuals engaged under civil law contracts.

For the effective management of compliance risks based on international best practices, the Company has developed its own set of "tools," including:

·        Measures to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction.

·        Measures to implement the "Know Your Customer" (KYC) principle, defining the necessary level of awareness about the client and their activities.

·        Measures to implement requirements in the area of embargoes and sanctions.

·        Measures to prevent the unlawful use of insider information and/or market manipulation.

If you become aware of facts of corruption, personal conflict of interest, or unethical behavior by Company employees, we would appreciate being informed through any convenient channel:

·        Sending a message to the email address of the Company's Authorized Unit for Corporate Ethics:  deontology@investnova.ru

·        Providing information by phone to an employee of the Company's Authorized Unit for Corporate Ethics: +7 (495) 215-10-83 ext. 22

·        Sending a letter to the postal address: 119415, Moscow, Ul. Udaltsova, d. 1A - to the Controller of the Professional Participant.