1. General Provisions
This Corporate Ethics and Anti-Corruption Policy Code (hereinafter referred to as the “Code”) has been developed to strengthen the business reputation of DOTA, LLC (hereinafter referred to as the “Company”), to promote honest and ethical business practices, and to prevent misconduct and legal violations.
The Code sets forth the Company’s standards and requirements regarding the observance of ethical and business principles and norms. It is not exhaustive. Where applicable, the provisions of current legislation take precedence. The Code outlines rules for the Company’s relations with shareholders, government authorities, individuals, and legal entities.
The provisions of the Code must be observed by Employees not only during working hours but also during off-hours activities, if such activities affect the interests of the Company or if the Employee is perceived by third parties as a representative of the Company.
The Company expects that its Clients will accept and share the commitment to conduct business in an honest and transparent manner. While the Company recognizes that Clients are independent entities, their business practices and behavior can significantly impact the Company, its reputation, and its brand — one of its most valuable assets. Therefore, the Company expects all Clients, along with their employees, agents, officers, and subcontractors, to adhere to this Code in the course of their business relations with DOTA, LLC. Clients will be introduced to the provisions of the Code by their primary contact persons within the Company.

2. Legal and Methodological Foundations
This Code was developed in accordance with the State Anti-Corruption Strategy of the Kyrgyz Republic (approved by Decree No. 26 of the President of the Kyrgyz Republic dated February 2, 2012), and in furtherance of the following regulatory acts:

• United Nations Convention Against Corruption (adopted on October 31, 2003);
• Council of Europe Criminal Law Convention on Corruption (adopted on January 27, 1999);
• OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (adopted on November 21, 1997);
• Decree of the President of the Kyrgyz Republic No. 137 dated June 5, 2024 “On the State Strategy for Combating Corruption in the Kyrgyz Republic for 2025–2030”;
• Other legislative and regulatory acts and methodological documents of the Kyrgyz Republic, the Company Charter, and internal documents;
• U.S. Foreign Corrupt Practices Act (FCPA), 1977;
• UK Bribery Act, 2010.

3. Terms, Definitions, and Abbreviations
Employee – an individual who has entered into an employment relationship with the Company.
Company – DOTA, LLC
Client (for the purposes of this Code) – any business entity having business relations with the Company, including government and municipal bodies and institutions, individual entrepreneurs, suppliers, contractors, subcontractors, joint venture partners, who purchase the Company’s goods or use its services.
Anti-Corruption Policy – an officially approved document defining a set of interrelated principles, procedures, and specific actions aimed at preventing corruption in the organization’s operations. The Anti-Corruption Policy applies to the head of the organization and all employees, regardless of position or function.
Corruption – abuse of official position, bribery, acceptance of a bribe, abuse of authority, commercial bribery, or other unlawful use by an individual of their position contrary to the legitimate interests of society and the state, in order to obtain benefits in the form of money, valuables, other property or services of a property nature, property rights for themselves or third parties, or the unlawful provision of such benefits by other individuals. Corruption also includes the above acts committed on behalf of or in the interests of a legal entity.
Conflict of Interest – any situation where the personal interest or activities of an Employee or their close relatives interfere or may interfere with the Employee’s ability to act in the best interests of DOTA, LLC, and to perform duties honestly, impartially, and effectively. Close relatives include:

• spouse;
• individuals in de facto marriage without state registration;
• parents, adoptive parents, guardians;
• children, including adopted;
• grandparents;
• grandchildren;
• full and half-siblings;
• nieces and nephews;
• aunts and uncles;
• the above relatives of the spouse.

Personal Interest – any interest that interferes or may interfere with the Employee’s ability to act in the Company’s interests, including the possibility of the Employee or their close relatives receiving income or other benefits beyond wages and legally authorized compensation.
Due Diligence – a principle based on reasonableness and good faith, requiring sufficient information to make well-founded decisions regarding counterparties or job candidates.
Bribery Prohibition (Offering) – prohibition on offering, promising, or giving any tangible or intangible benefits, directly or through intermediaries, to influence decisions in one’s favor or for third parties.
Bribery Prohibition (Receiving) – prohibition on accepting, agreeing to accept, or receiving tangible or intangible benefits, directly or through intermediaries, in return for actions or omissions benefiting the bribe-giver or third parties, falling within official duties.
Prohibition on Bribing Foreign Public Officials – prohibition on offering, promising, or giving any benefits, directly or through third parties, to foreign officials to influence the performance of their official duties in favor of a commercial organization.
Anti-Corruption Commission (the Commission) – a body created by the Company to receive Employee reports on Code violations, assist with conflict resolution, and prevent or stop fraud and corruption.

4. Core Principles and Values of Business Conduct
The Company declares the following core principles and values of honest and ethical business conduct, which are to be strictly observed:
Company's Responsibility to Employees:

• Respect for all employees;
• Prohibition of harassment and offensive behavior;
• Ensuring a safe workplace;
• Protection of personal data confidentiality;
• Social responsibility through proper health management, timely salary payments, and contributions;
• Improving employee training and motivation;
• Considering individual performance;
• Use of voluntary labor only;
• Use and compensation of voluntary overtime according to applicable laws.

Employees’ Responsibility to the Company:

• Protect the Company’s reputation;
• Perform duties conscientiously;
• Comply with internal Company policies;
• Avoid misuse of internal information;
• Avoid competing with the Company for personal gain;
• Protect the Company’s intellectual property;
• Use Company resources efficiently and responsibly.

Responsibility to Clients:

• Adherence to professional standards;
• Protection of client confidentiality;
• Special care in situations involving potential Conflicts of Interest;
• Fulfillment of legal obligations;
• Avoidance of abuse of rights;
• No unjustified privileges;
• Avoidance of defamatory statements.

General Business Responsibility:

• Never give or take bribes;
• Conduct business honestly with clients, suppliers, and competitors;
• Comply with this Code, competition, anti-monopoly, anti-money laundering, and anti-corruption laws;
• Carefully select business partners, clients, and suppliers;
• Provide truthful information in marketing and advertising.

Responsibility to Society:

• Comply with the law and act responsibly;
• Respect local laws of countries where the Company operates;
• Conduct operations transparently.

The Company declares all the above principles to be equally important and does not prioritize any over others. It must maintain balance among all principles and rejects all forms of discrimination, including political, national, gender, or other bias.

5. Combating Corruption, Fraud, and Preventing Conflicts of Interest
In both Kyrgyzstan and abroad, Employees interacting with Clients, government bodies, other organizations, and individuals must avoid actions contrary to Kyrgyz law, this Code, or applicable laws in countries where the Company operates.
Employees are prohibited from offering, giving, or receiving any incentives, gifts, rewards, loans, guarantees, financial aid, cash or equivalents, securities, precious metals, stones, or jewelry if it may result in a Conflict of Interest or harm the Company’s reputation.
The Company implements internal control measures to detect and address such risks. Employees must not participate in or assist others in violating applicable laws, policies, or procedures.
Respecting Clients’ and partners’ ethical standards, the Company prefers to work with those aligned with its ethical norms.
If a Client or partner violates core human rights or anti-corruption standards, the Company may refuse cooperation.
Information about competitors, clients, and partners is obtained legally, avoiding any unlawful practices.
In the case of a potential Conflict of Interest:

• Employees should seek clarification via the Company’s “Hotline” or directly from the Committee.
• Employees should refrain from involvement in related decisions until guidance is received.
• Conflict information is reviewed according to internal policies and this Code.
• Any suspected fraud, corruption, or Conflict of Interest must be reported immediately to a supervisor, the Hotline, or the Committee.

5.1. Hotline
The Company appreciates adherence to this Code and aims for mutually beneficial relationships with all Clients based on ethical standards. Third parties are encouraged to report known violations.
Ways to report include:

• Hotline: +996 505 07 51 81 (Available 9:30 AM to 6:30 PM Mon–Fri; voicemail outside those hours)
• Email: legal@dota.kg
• Mail:
• Legal address: 720007, Bishkek, Lenin District, Anarbek Bakaev St., 7
• Physical address: 720040, Kyrgyz Republic, Bishkek, Razzakov St., 32
• Recipient: Management, DOTA, LLC

Confidentiality is strictly maintained. Each report is reviewed by the Committee, and if necessary, an investigation is conducted.
Employees may also contact the Hotline or Committee for clarification of anti-corruption rules.
The Company expects Employees to act with honesty, integrity, and responsibility when providing information.

5.2. Disclosure of Information
Employees must not disclose trade secrets, private life, or health-related information obtained during their work, nor information affecting dignity and honor. Confidentiality must be maintained in all communications.
Employees agree not to disclose trade secrets even after termination of employment. Unauthorized disclosure may result in liability.
Insider information must not be misused. Internal policies and this Code govern its use.
Employees must follow software and database access and security protocols.
Disclosure of trade secrets or insider information by the Company follows the law, charter, and internal policies and must not include false information.

5.3. Protection Against Retaliation
The Company protects Employees from retaliation — including dismissal, demotion, harassment, loss of benefits, or discrimination — if they in good faith seek advice or report suspected misconduct or violations of this Code, including anonymously.
If an Employee experiences retaliation, they may contact their supervisor, the Hotline, the Commission, or senior management.
The Company ensures that the identity of anonymous whistleblowers remains confidential and that no retaliatory action will be taken if the person’s identity becomes known during an investigation.

6. Measures to Prevent Corruption

6.1. Restrictions on Giving/Receiving Gifts and Representational Expenses
The provision of gifts and other material and immaterial benefits, as well as representational expenses, is carried out in accordance with the Company’s internal regulations. Gifts to Company Employees, clients, business partners, and government-related individuals must not influence their ability to make unbiased and fair business decisions.
Company Employees may give or receive Gifts of reasonable value to or from Clients and business partners, provided such Gifts cannot be construed as inducements for making decisions in favor of the giver.
All Gift-related expenses must be properly and accurately reported in expense reports and recorded in the Company’s accounting records.
The Company allows gift exchanges and representational events only if they meet the following criteria:

• Business breakfasts, lunches, dinners, and representational events, provided the purpose of the meeting or event is business-related;
• Corporate gifts bearing the giver's logo (e.g., diaries, calendars) and gifts given during annual, professional, and other recognized holidays (e.g., New Year, Christmas, anniversaries, etc.);
• Promotional materials may be accepted if they are given voluntarily and cannot influence the Employee’s decision-making;
• Gifts and awards for achievements or contributions to development from the Company, public, charitable, or religious organizations within the value limits established by law.

It is important to note that:

• Gifts must be related to the Company’s legitimate interests, in particular, promoting its products or services in good faith or commemorating customary or professional holidays;
• Decisions on giving gifts or other material benefits must comply with the Company’s internal regulations and the principles outlined in this Code.

6.2. Refraining from Political Activities
The Company does not participate directly or indirectly in political parties, organizations, or related foundations, including providing sponsorship or other payments in their support.
Company Employees may, as private individuals and during their personal time, engage in political activities at their own discretion, provided such participation does not harm the Company's interests or create a conflict of interest.

6.3. Proper Interaction with Government Representatives and Public Organizations
The Company interacts with law enforcement, regulatory authorities, other government and municipal bodies, their representatives, as well as with public organizations and their representatives, strictly within the framework of applicable legislation.
The Company does not make illegal payments to the above-mentioned entities or individuals, including through intermediaries, such as payment for travel, entertainment, transportation, or other expenses, with the intent to gain or retain business advantages.

6.4. Proper Interaction with Counterparties, Intermediaries, and Payments to Third Parties
The Company refrains from offering material incentives to representatives of counterparties, including through services, cash payments, or gifts, in order to influence decisions in the Company’s favor.
Company Employees are prohibited from engaging intermediaries, agents, or other persons to carry out activities that contradict applicable laws, this Code, or other internal regulations of the Company.

6.5. Accurate Record-Keeping
The Company adheres to legal requirements and accounting standards. Each business transaction must be documented with a primary accounting document. Distortion or falsification of accounting, management, or other records or supporting documents is prohibited.
All financial transactions must be recorded accurately, truthfully, and with the necessary level of detail.
Employees responsible for maintaining records are accountable for the timely preparation and submission of complete and accurate reports. Intentional misrepresentation or falsification of reports is prohibited and subject to legal action.

6.6. Control and Audit
The Company regularly conducts internal and external audits of its financial and business activities. It monitors compliance by Employees with anti-corruption laws, this Code, and other internal regulations. Revisions and improvements are made as necessary.

7. Responsibilities of Employees and Other Persons in Combating Corruption
Company Employees familiarize themselves with the provisions of this Code and sign a commitment to comply with its rules. This commitment is attached to the employment contract as per Appendix No. 1 of this Code.
Employees must strictly comply with the restrictions and requirements set forth in this Code, including those related to:

• Giving and receiving gifts;
• Representational expenses and sponsorship;
• Political activities;
• Interaction with government representatives, public organizations, counterparties, intermediaries, and third parties;
• Avoiding conflicts of interest;
• Maintaining accurate records.

8. Liability for Non-Compliance or Improper Compliance
All Company Employees, regardless of position, bear personal responsibility for non-compliance or improper compliance with this Code, as provided by applicable laws of the Russian Federation and the Company's internal regulations.
If there are suspicions of corrupt activity, the Anti-Corruption Committee conducts an internal investigation, the results of which are reported to Company management. Each situation will be thoroughly examined and decisions will be based on the facts and applicable laws.
Employees who violate this Code may be subject to disciplinary action in accordance with the labor laws of the Kyrgyz Republic and the Company's internal regulations. In the case of minor violations, recommendations may be given to adjust behavior in accordance with this Code’s principles.
Company Employees, Clients, and third parties must ensure the information they provide is accurate. Deliberately providing false information, obstructing, or refusing to cooperate during internal investigations is a violation of this Code. The Company does not tolerate retaliation against employees who report potential violations or corruption in good faith.
The Company reserves the right to seek legal remedies against individuals whose actions violate this Code and cause harm to the Company.
The Company also reserves the right to refer cases to law enforcement for administrative or criminal prosecution if the actions in question meet the criteria for such offenses under the law.
Information about violations of this Code may be publicly disclosed (in compliance with personal data protection laws), including on the Company’s corporate website, official online platforms, or through mass media.
Managers are responsible for ensuring their team members comply with the provisions of this Code.

9. No Third-Party Rights
This Code does not grant any rights to third parties. The Company reserves the sole right to determine how to handle the actions described in this Code at its own discretion.