Code of Ethics

CODE OF ETHICS

Approved by the company Concern Achema Group

Board meeting protocol No. 48045

2004-04-15

An ethical human performance and good business practice is the guarantor for the reliability and good reputation of the whole Concern Achema Group.

MAIN VALUES

HONESTY AND MORALITY

Only honesty and trust-based relationship ensures long-term business success. Deceit, dishonesty and intentional actions which are detrimental to the Concern would not be tolerated.

CLIENTS

Customers are the foundation of our business. The Concern Achema Group has to cooperate with customers and meet their needs in order to a success.

PERSONNEL

People are the most valuable asset of the Concern Achema Group. Personnel accumulate skills, competence and potential of teamwork to achieve success.

RESPONSIBILITY FOR THE PUBLIC

The Concern Achema Group acknowledges and willingly accepts the responsibility for the public. The Company is committed to protect people environment and natural resources by choosing a reliable mode of producing.

THE WORK EFFICIENCY

In order to work efficiently in all operational areas the Concern Achema Group takes the principles of fairness, impartiality and transparency in business. Excessive spending or overspend of the Company assets aren’t tolerated.

SAFETY AND HEALTH

Personnel must take care of their health and safety at work. Everyone must comply with the health and safety requirements, rules and procedures.

PROGRESS AND CHANGES

There is no progress without changes. Innovations and desire to excel, initiative and responsible approach to work, opens up new opportunities and creates basis for the success of the Group.

GENERAL PROVISIONS

MANAGEMENT

Managers have to introduce business principles to their employees, clearly formulate tasks, explain their choices and decisions, encourage and create conditions for constructive discussions. They don't tolerate illegal practices, inappropriate behavior, harassment actions in work place, discrimination of the colleagues or subordinates.

PERSONNEL

The Concern values staff competence, activity, creativity and practice. The Company respects a fair and respectful behavior, provides equal career and self-expression opportunities. Employees feel a personal responsibility for their actions and performance in the Company. They are loyal to the company and continuously improving relationships with business partners and customers.

HEALTH, SAFETY AND ENVIRONMENT

Actions of the companies must meet health, safety and environmental requirements. They should act in accordance with the law and safety regulations. The Companies should work in a healthy and safe working environment and provide opportunities for quality relaxation. Staff takes personal responsibility for health and safety standards, rules and procedures.

COMPETITIVENESS

The Concern follows principles of honest and ethical competition, while respecting and objectively assessing other market participants. Personnel are working in compliance with law, regulations and resolutions that set a fair competition in the market.

THE OBJECTIVES

Key business objectives of the Concern Achema Group are:

- impeccable reputation of the group;

- trust of the shareholders, employees, customers and business partners;

- favorable public reaction.

PRINCIPLES OF BUSINESS

The Concern Achema Group works by the principles of transparency and objectivity. A main criterion of decision making managers and employees is to achieve maximum benefit for the Group. The Company does not tolerate proposals that either directly or indirectly contradicts with the law. All transactions in the Company are audited. Records are kept accurately and precisely.

ASSET PROTECTION AND USE

The Concern Achema Group asset is not only technical or organizational equipments, various resources, materials, but also information and intellectual property - inventions, copyrights, trademarks, technologies and other. The assets are used only for legitimate business interests. Personnel treat the assets of the group with responsibility ensuring proper activity and preventing unauthorized capture and other violations.

CONFLICT OF INTEREST

Employees must avoid intersection of private and common interests. There shouldn’t be any actions that may affect the reputation of the Company. The Company does not tolerate personal interests or commitments that contradict with the legitimate business.

GIFTS AND REPRESENTATION

Business gifts and representational activities help to strengthen relationships with business partners and customers. Under these circumstances the employees may accept or offer gifts and souvenirs if it isn’t required for any service or obligation. Company does not tolerate gifts that affect business activities.

CONFIDENTIALITY AND INFORMATION

Confidential information is a base of the business strategies. Employees are responsible for the storage of such information, while maintaining the advantages of the Group in competitive market.

Confidential information includes assets, financial, technical information, details about the shareholders, employees or customers. Workers without special permission mustn’t disclose any information to a person who is not employed in the Company even if he is a family member or a friend. The confidential information is provided within the Company only when it is necessary. Employees are required to protect it against the loss, theft, unauthorized use or modification.

POLITICAL AND SOCIAL ACTIVITIES

The Concern Achema Group isn’t participating in any political parties or activities of other organizations. However it informs about position on the issues which have a direct impact on the activities of the Group.

The Company supports non-profit and non-governmental organizations, in accordance with the law. Employees may participate in political activities and elections. They may run election campaigns and raise funds, but they must clearly distinguish the line between personal and activities of the group.

THE PROVISIONS

Employees who are aware of or suspect that there are violations of the principles and Ethic code must apply to immediate superior or group lawyer. The penalties provided by law, including contract termination could be used for those who had violated the principles of business ethics or ethic code.