Declaration of Conflict of Interest

Typical Conflict of Interest Declaration, according to Appendix No. 4 to the Methodological Recommendations of the Ministry of Labor of Russia contains three sections. To the question: "Who should fill it?" - I answer: the first and second sections of the declaration of the conflict of interests are filled by the employee of the organization, and the third section is filled by his immediate superior.

An employee is required to disclose information about each actual or potential conflict of interest. And this information is subject to subsequent comprehensive verification by the director of the institution in accordance with the established procedure.

This document is strictly confidential( for completion) and is intended solely for the internal use of the enterprise. The content of this document is not subject to disclosure to any third parties and can not be used by them for any purpose. The period of storage of the declaration of a conflict of interests is one year. Its destruction occurs in accordance with the procedure established in the organization. So. ..

Model of a standard conflict of interest declaration

of

Before completing this declaration, I have read the Code of Ethics and internal organizational behavior, anti-corruption policy, the Regulation on conflict of interests and the Regulation "gifts and business entertainment."

Next, after this "cap" is the signature of the employee

To: ( indicating the full name and position of direct superior)
From( the full name of the employee who filled out the Declaration)
Position:
Date of filling:
The declaration covers the period of time	with. .........by ……………….

You should carefully read the questions below and answer "yes" or "no" to each of the questions. The answer "yes" does not necessarily mean a conflict of interest, but reveals a question that deserves further discussion and consideration by the immediate superior. It is necessary to give an explanation to all the answers "yes" in the place reserved at the end of the first section of the form. When filling out the Declaration, it is necessary to take into account that all the questions put forward are not only for you, but also for your spouse( or partner in a civil marriage), parents( including reception rooms), children( including reception rooms), relatives andcousins ​​and sisters.

Section 1.

External Interests or Assets

1. Do you or anyone acting in your interests, directly or as a beneficiary, shares( shares, shares) or any other financial interests:

1.1.In the organization's assets?

1.2.In another company in a business relationship with the organization( contractor, contractor, consultant, client, etc.)?

1.3.In a company or organization that may be interested or looking for an opportunity to build business relations with the organization or negotiate with it?

1.4.In the activities of a company-competitor or a physical person-competitor of the organization?

1.5.In a company or organization acting as a party to litigation or arbitration with the organization?

1. If the answer to one of the questions is YES, then do you have written permission from the relevant body of the organization authorized to resolve conflicts of interest, or the manager to whom the relevant authority was delegated?
2. Are you or the persons acting in your interests, members of the management bodies( Board of Directors, Management Board) or executive directors( directors, deputy directors etc.), as well as employees, advisers, consultants, agents or proxies:

3.1.In a company in a business relationship with the organization?

3.2.In a company that is looking for an opportunity to build business relations with an organization, or is it negotiating with it?

3.3.In the company-competitor of the organization?

3.4.In a company that acts or intends to be a party to litigation or arbitration with the organization?

1. Do you currently participate in any activity other than the one described above that competes with the interests of the organization in any form, including but not limited to the acquisition or disposal of any assets( assets) or business development opportunities or business opportunities,projects?

Personal interests and honest business conduct

1. Did you participate in any transaction on behalf of the organization( as the person making the decision, responsible for the performance of the contract, approving the acceptance of the work performed, processing or approval of payment documents, etc.), inwhich you had a financial interest in a counterparty?
2. Have you ever received cash or other tangible assets that could be interpreted as affecting in an illegal or unethical manner the commercial transactions between the organization and another entity, for example, the counterparty's fee for facilitating the deal with the organization?
3. Have you ever made payments or authorized payments to an organization that could be interpreted as affecting in an illegal or unethical manner a commercial transaction between an organization and another entity, for example, payment to a counterparty for services rendered to an organization that exceeds the size in the prevailing market conditionsremuneration reasonably due for services actually received by the organization?

Relations with civil servants

1. Have you ever made payments, offered to make any payment, authorized the payment of cash or other tangible assets, directly or through a third party, to a government official, candidate for authority or a member of a political party to receive unreasonable privilegesor influencing the actions or decisions taken by the state institution, in order to preserve the business or acquire new business opportunities, the organizationns?

Insider information

1. Did you disclose to any third parties any information about the organization:( 1) which could have a significant impact on the value of its securities on stock exchanges in the event that such information becomes widely known;(2) for the purpose of buying or selling by third parties securities of an organization on stock exchanges to your personal benefit or the benefit of third parties?
2. Did you disclose in your personal, including financial, interests to any person or company any confidential information( plans, programs, financial data, formulas, technologies, etc.) that belong to the organization and have become known to youwork or developed by you for the organization during the performance of their duties?
3. Did you disclose in your personal, including financial, interests to any third party physical or legal person any other information related to the organization that has become known to you on the job?

Organization Resources

1. Did you use the organization's resources, time, equipment( including communications and Internet access) or information in such a way that it could damage the reputation of the organization or cause conflict with the interests of the organization?
2. Do you participate in any commercial and economic activities outside of employment in the organization( for example, part-time work) that contradicts the organization's requirements for your working time and leads to the use of assets, resources and information owned by the organization for the benefit of a third party?

Equal Rights for

1. Employees Do your family members or close relatives work in the organization, including under your direct supervision?
2. Does any member of your family or close relative work in the organization, which allows you to influence the evaluation of the effectiveness of your work?
3. Have you provided protection to your family members or close relatives when they are employed by the organization;or gave an assessment of their work, whether you promoted them to a higher position, did you evaluate their work and determine their salary or exempted from disciplinary responsibility?

Gifts and business hospitality

1. Did you violate the requirements of the Regulation "Gifts and business hospitality"?

Other issues

1. Do you know of any other circumstances not mentioned above that cause or are likely to cause a conflict of interest, or may create the impression of your colleagues and managers that you are making decisions under the influence of a conflict of interest?

If you answered "YES" to any of the above questions, please provide details below for full consideration and assessment of the circumstances.

Section 2

Income Statement

1. What income did you and your family members receive in the place of their main work for the reporting period?
2. What income did you and your family members receive in the place of their main work for the reporting period?

Statement

I hereby confirm that I have read and understood all of the above questions, and my answers and any explanatory information are complete, truthful and correct.

Signature: __________________ Full name: ______________________

Section 3

I have verified the reliability and completeness of the information stated in the Declaration:

__________________________________

( name, signature)

With participation( if necessary):

Representative of the head of

_____________________________________________

Name, signature)

Representative of the Internal Audit Department

_____________________________________________

( Name, signature)

Security Representative

_____________________________________________

( Name, signature)

Having submittedTel legal service

_____________________________________________

( name, signature)

representative of the personnel department

_____________________________________________

( name, signature)

decision supervisor of

Declaration( confirm by signature):

Conflict of interest was not detected

I do not view as conflict of interest a situation which, in the opinion of the employee who declared them, creates or may create a conflict with the interests of the

organization. I have limited the employee access to information of the organization that may be relevant to his personal private interests of the employee [indicate which information]

I removed( permanently or temporarily) the employee from participating in the discussion and decision-making process on issues that are or may be affected [indicate from which questions]

I have revised the terms of reference and employment functions of the employee [indicate which duties]

I temporarily suspended the employee from the position that leads to a conflict of interest between his job duties and personal interests

Itransferred the employee to a position providing for the performance of official duties not related to the conflict of interests of

. I applied to the higher management for the dismissal of the employee for incompetenceAtiv organization for disciplinary offenses according to the current legislation

I passed a declaration supervisors to check and determine the best way of resolving conflicts of interest due to the fact that. .................