Valid from July 20, 2024
These Rules of Business and Corporate Ethics (hereinafter referred to as "these rules") apply to all employees of the Media Bot, as well as to members of the Board of Directors. These rules are based on the principles set out in applicable legislation and in international documents: Universal Declaration of Human Rights, The Guiding Principles of Business Activity in the context of Human Rights of the United Nations, ILO Conventions, Principles of the UN Global Compact.
The media bot strives to adhere to the highest standards of business ethics when conducting business activities. The company expects that we will also adhere to the requirements of business ethics by participating in business activities on behalf of the Media Bot.
The media bot adheres to the principle of zero tolerance for any violations of the rules of corporate ethics.
These rules include provisions that are mandatory for all employees of the Media Bot Group companies and members of the Board of Directors. Failure to comply with these rules can lead to negative consequences, including legal ones, both for us and for the Media Bot.
We should study these rules, as well as other policies, rules and The principles adopted in the Media Bot. Each of us is responsible for ensuring that we all comply with the requirements of legislation, other regulations, as well as the requirements of business and corporate ethics applicable to the activities of a Media bot. It is the responsibility of each of us to know and understand the provisions contained in these rules, as well as to comply with the policies and rules adopted in the Media Bot. Managers must take the necessary measures to ensure that their team members understand and comply with the requirements of these policies and rules.
It is important for us that our business partners also adhere to ethical behavioral practices: Supplier Code of Business Conduct.
1. We work for users
2. Working in a Media bot
3. Compliance with the law
4. Conflict of interest
5. Confidential information
6. Making deals
7. Environmental responsibility
8. Reporting
9. Complaints and liability for violation of the rules
10. Making changes and deviations from the rules
1. We work for users
The key goal of our activity, and this is reflected in various internal documents of the Media Bot, is to provide high-quality services for millions of Internet users. It is extremely important that each of us strive to achieve this goal. First of all, we think about the user characteristics of the service, how much people will like and use it.
The company expects all of us to be responsible not only for our part of the work, but also for the product as a whole.
Be not indifferent to user reviews. Suggest improvements. If you notice that something is not working or is not working correctly on one of the Media Bot services, be sure to inform the responsible managers about it.
Our business is largely based on the high reputation of the Media Bot and the trust of our users. This trust is the result of many years of hard work by many people and one of the core values of the Media Bot brand.
Keep in mind that when using our services, people trust us with their data. This may be the user's personal information (for example, passport or payment data), our correspondence with him, knowledge of his social connections, and much more. Our internal procedures restrict access to any non-public user information. It is strictly confidential and can only be used for the purposes for which it was collected. When working with such personal data, you must keep them confidential and prevent their disclosure and dissemination.
Equal rights
We consider discrimination unacceptable in making any work decisions — nationality, gender, race, political or religious views, sexual orientation and other characteristics unrelated to a person's professional qualities and performance of official duties do not matter to us. When applying for a job, the Media Bot provides all candidates with equal opportunities. We hire those who are able to best cope with the proposed tasks. We respect human rights and support the protection of these rights. The use of illegal child and forced labor in any form is unacceptable in the Media Bot. Any exploitation of a person by a person is unacceptable, therefore, cooperative principles are applied in the Media Bot.
Working relationship
We should be guided by exactly the same principles in professional communication. Violence or threats of violence, insults, rude statements on topics of gender, race, nationality, religious and political views, sexual orientation, and so on are unacceptable in a media bot. Any form of sexual harassment — unwanted sexual acts against another person - is also prohibited. Such actions are strictly suppressed.
Working hours, wages, occupational safety and health
The media bot complies with applicable local laws governing labor relations (including wages, working hours, overtime).
The Company recognizes the right of employees to freedom of association and collective bargaining and respects this right, as well as the right to the result of their work, including personal contribution to the result of collective work.
We consider it important that the Media Bot be and remain a safe place to work, therefore, we commit ourselves to ensuring safe working conditions and monitoring the level of exposure of employees to harmful and dangerous industrial factors, as well as taking the necessary measures to prevent emergencies.
The media bot monitors the proper condition of the equipment, informs employees about the rules of labor protection, and, if necessary, provides personal protective equipment.
The Company undertakes to identify and eliminate the causes of incidents, keep appropriate records of them, and provide affected employees with the opportunity to receive the necessary medical care.
The offices of the Media Bot are arranged in such a way that employees can work in them as conveniently, comfortably and safely as possible, as well as spend time after work.
Company property and resources
The company provides us with everything we need to work. This is the property of a Media bot. The company expects us to treat it with care. Despite the fact that the use of such resources for personal purposes is not prohibited, the company expects that we will use them responsibly and within reasonable limits. Maintaining offices in such a way that it is pleasant and comfortable to work in them is also the work of our colleagues, which we respect.
We have open offices, and all employees can bring their guests. At the same time, remember that you are fully responsible for ensuring that your guests do not interfere with anyone's work and that confidential information does not leak. While the guests are in the office, they should not be left alone, unaccompanied.
Intellectual property
Our intellectual property includes, among other things, the logo, trademarks, patents, software products, etc. These are very important and valuable assets of a Media Bot, and any use of them by our external partners or use for external events must be agreed in advance with the head of the PR service. If you come across an object of intellectual property of a Media bot and you doubt the legality of its use, please report it to the legal department.
The media bot respects the intellectual property of third parties. Misuse of someone else's intellectual property can lead both a team member and a Media bot to lawsuits and fines, as well as negatively affect our reputation. If your project involves the use of any content or software that does not belong to a Media bot, you should definitely consult with lawyers.
3. Compliance with the law
It is the responsibility of each of us to comply with the requirements of applicable legislation. We expect each of us to comply with the requirements of applicable laws and other regulations when carrying out activities on behalf of a Media Bot. It is important to know the legal requirements, because we have services, some of the functions of which may depend on the legislation of a particular country.
We must comply with the requirements of applicable legislation governing import, export and other trade aspects of business activities in the countries of our presence. In addition, it is necessary to comply with trade and economic sanctions restrictions imposed in various states, if they apply to our companies, team members and the activities of the Media Bot.
We must take into account that part of the legislation of all countries and territories of our presence that directly relates to our professional duties, that is, regulates the provision of that service in a certain country and in a certain territory for which we are responsible. For advice, you need to contact the lawyers of the Media bot, and this must be done at the design stage of the service.
Bribery is a crime in all countries where the Media Bot is present. We strictly prohibit any form of bribery, including bribes, commercial bribery, as well as other types of illegal payments in order to obtain or maintain advantages in carrying out business activities or obtaining approvals from regulatory authorities. We must follow the requirements of the policy regarding receiving gifts and entertainment. We prohibit making such illegal payments even if such payments are acceptable in certain places where the Media Bot is present. It should be remembered that local customs or practices are in no way an excuse for committing a crime.
We must not offer, give, demand or accept money or valuable gifts, services, etc. for the purpose of (1) obtaining, maintaining advantages in carrying out business activities, (2) guaranteeing or receiving any more favorable treatment. A direct or indirect promise of a bribe is equivalent to giving a bribe in accordance with the law. When we make a decision on behalf of a Media Bot to purchase any resources or services, we should choose contractors impartially, taking into account the competitiveness of the prices offered, the quality of goods or services, as well as the reliability of potential suppliers. We must not accept bribes or other illegal or inappropriate payments, gifts or services.
The Company is committed to the principle of fair, fair and free competition and undertakes to conduct business in full compliance with antitrust and competition laws in force in the regions in which the company operates.
4. Conflict of interest
We have certain obligations to the Media Bot. In particular, the company expects that in our professional activities we are guided primarily by the interests of our users and our common interests as a team. A conflict of interest is a work situation in which there is a contradiction between the personal interests (or the interests of your friends, close relatives, partners) and the interests of the Media Bot team.
In the context of corporate ethics, close relatives include parents, children, siblings, official and de facto spouses; people with whom you are in a romantic relationship, and any other people important to you who may influence your work decisions.
To understand how much a particular situation contains a conflict of interest, think about how it looks from the outside. Can you tell your boss and other colleagues about it? If a description of this situation appears in newspapers and blogs, how will it affect the Media Bot? Each of us should avoid conflicts of interest, as well as situations that can be interpreted as a conflict of interest.
Corporate opportunities
You cannot use for personal purposes (or use for your close relatives or friends) any opportunities that the company's resources, information or position open up to you. These opportunities are the sole and exclusive prerogative of the Company. For example, if you find out about a potential deal with a Media bot as part of your job responsibilities, you will not be able to independently conclude this deal on your behalf - this right belongs to the Media Bot. It is your duty and responsibility to promote the legitimate interests of the Company whenever the opportunity arises.
Work and personal life
You cannot use your position in a Media bot to benefit close relatives, friends and partners: this is a conflict of interest between the company and your friends or relatives. Conflicts of interest when working with close relatives happen:
- if one of the relatives works under the other;
- if relatives are involved in the same business process or both are involved in decision-making on the same interdependent issues and other employees of the Media Bot are not involved in decision-making.
However, conflicts of interest should be avoided when working together not only with close relatives, but also in any form of relationship, when the impartiality and independence of your decisions may suffer.
For example, if you have a loved one working under you, there is a possibility that you will provide him with more favorable working conditions, and evaluate the results more loyally than the results of other employees. And even if your decisions are not influenced by a special attitude towards this person, other employees may believe that this is not the case. In this case, it is worth conducting surveys and discussions with colleagues to get a more objective picture and eliminate this conflict.
Combining work in a Media bot with other work
Each of us can work part-time or engage in personal business in our free time. However, such work should not conflict with working in a Media bot. Combining work in a Media bot with other professional activities may lead to a conflict of interest if:
- at the same time as working in a Media bot, you work for a competing company or consult with it;
- you use or can use the results of your work or the work of your colleagues in the Media Bot or the equipment, premises, software of the Media bot to perform other work;
- you use or can use your official position and authority in the Media Bot to obtain favorable conditions for your second company or your business;
- you use the Media Bot's working hours to do other work;
- you use the confidential information of the Media Bot to perform work outside the company or to obtain favorable terms for another company or business that you own, participate in or are interested in.
The best solution would be to coordinate this combination with colleagues and management.
Business gifts and hospitality
One of the situations that can create a conflict of interest or look like a conflict of interest is accepting gifts, gratuitous services, or signs of hospitality from partners (for example, entertainment, trips, lunches or dinners).
The media bot expects that all gifts and hospitality that we receive or provide will comply with the following principles:
- have a reasonable cost;
- do not create a conflict of interest;
- are legal;
- comply with local customs and business rules;
- do not make the recipient feel obligated;
- are not and do not give anyone a reason to consider them a bribe or commercial bribery;
- should not be extorted by the recipient.
The company has procedures for approving gifts that must be followed when giving or receiving gifts.
How do we accept gifts
We should not accept expensive gifts from business partners, the cost of which exceeds 11 thousand rubles, as well as money and cash equivalents (certificates, e-money cards, etc.), regardless of their nominal value.
It is acceptable to accept standard products of service partners as a gift: subscriptions and other marketing products of partners (promo codes, certificates, discounts, etc.) if their annual cost does not exceed 11 thousand rubles or this is done within the framework of agreed promotions.
It is important to remember that when accepting such gifts from a partner, you need to be guided not only by the acceptable value of the gift, but also by whether you personally make business decisions regarding this partner. For example, you can accept discounts from a partner if they apply to all employees. But if a partner offers such a gift for the personal use of a certain employee, then additional approval will be required in accordance with the company's procedures. Gifts of minor value (and not in the form of money), such as flowers, fruit baskets, pens and other promotional items, can be accepted. You can also accept invitations to business breakfasts, lunches, dinners or festive events — unless you believe that this invitation complies with the above principles and is not a means to influence you.
There are no more universal definitions here, so you need to think about each specific situation. For example, you can accept a notebook, but not a new iPhone or an expensive watch. If we are talking about a collective gift, for example, for all employees of a particular department, evaluate how expensive a gift each of them receives as a result. It is also worth considering if a partner offers you to go on vacation at his expense or invites you to an event abroad and promises to pay for your business class flight and a suite at the hotel.
How we give gifts
We try to comply with the same rules by providing gifts and hospitality to our partners. We also do not want to create a sense of conflict of interest in relation to them.
You can give business gifts within the acceptable cost and corresponding to the principles of business gifts of a Media bot, branded souvenirs of a Media bot, standard discount products of a Media bot, including promo codes and other standard discount products, subscriptions of Media bot services, if the annual cost does not exceed the acceptable cost or it is done within the framework of agreed promotions.
It is unacceptable to give money and cash equivalents to partners (cash certificates, e-money cards, etc.) regardless of their nominal value.
In addition to these rules, local laws or regulations may prohibit or severely restrict the provision of gifts or hospitality to government employees (for example, employees of ministries, departments, services). Therefore, before giving something to a government employee or inviting him somewhere at the expense of a Media bot, make sure that this does not violate local legislation. Some types of gifts, including those that go beyond the above rules, require prior approval according to the procedures established in the company.
Other examples of conflict of interest:
- if you have a stake or other significant interest in a company that competes with a Media bot or is a supplier or client of a Media bot;
- if in a transaction that you make on behalf of a Media bot, you have personal financial interests that can influence your decisions;
- if you use the name of the Media bot for personal purposes, for example, for your personal business. We have to take a survey regarding conflicts of interest when it is conducted by a Media bot. Each of us must notify the Media Bot about each case of a conflict of interest through a survey form.
Privacy
We have a lot of confidential information that concerns our technologies, partnerships, finances, etc. For example, this is technical information about the functioning of our products and services, user data, user logs, product promotion strategies, planned transactions, business plans, financial results of the Media bot before their public announcement. Disclosure of such information can cause significant harm to a Media bot, therefore it is prohibited before public disclosure, and when applying for a job, each of us signs an Obligation not to disclose confidential information and agrees to comply with the Trade Secret Provision.
Even if you think that due to your job responsibilities you do not have access to any confidential information, working in a Media bot, it is quite difficult not to find out anything secret. For example, you can hear a conversation between colleagues or find a printed document in the printer. Remember that you have committed not to disclose any confidential information (even to colleagues if they do not have access to such information) and use it only for the performance of your official duties. You should not attempt to gain access to confidential information unless your official duties imply obtaining such access.
Information security
One of the important aspects related to maintaining the confidentiality of information is compliance with the requirements of the information security service. If you: notice suspicious network activity, computer behavior similar to a manifestation of a virus infection; suspect that some Media Bot services have been hacked, or know about other security violations, be sure to inform the information security service.
Communication with the outside world
In answering questions from third parties related to the Media Bot, follow common sense, the recommendations of the PR service, as well as the Provision on Trade Secrets of the MEDIA BOT. In the process of negotiations with partners, a situation may arise when you need to provide certain confidential information. This can only be done by signing a Non-disclosure Agreement with a partner. Please make sure that this agreement is actually signed before you tell us anything secret.
When communicating with colleagues from competing companies, do not specifically try to find out anything confidential. There are companies that we compete with, and we do it honestly, without trying to get their secrets. If your friends or close relatives work in competing companies, please be careful when talking to them about professional topics.
When interacting with government authorities in the countries of presence, it is necessary to follow the recommendations of the GR-service of the Media bot (Department of Corporate Relations). You can communicate with government officials on behalf of a Media Bot only if you are authorized to do so. When communicating with officials, you can only express the official position of the Media bot. If you do not know the position of the Media Bot on a particular topic, you should forward the question to the GR managers. If questions are received from the media, they should be forwarded to the PR service.
6. Making deals
When making deals, we must always strive for the best deal and always act in the best interests of the Media Bot team. It is important to pay attention not only to the cost, but also to other factors, such as the reputation of the company with which we are starting to cooperate.
The Media Bot has internal procedures governing the access of certain employees to funds, as well as giving some people the right to sign contracts on behalf of the company. Information about who can sign and approve certain expenses and contracts is contained in internal documents.
We expect all people authorized to sign contracts and manage any amounts from the Media Bot's budget to be attentive and take a reasonable approach to spending, and signing contracts only after receiving the necessary internal approvals. If you sign a contract, make sure that you understand everything in it and agree with everything. All contracts must be approved in accordance with internal procedures. Before entering into a contractual relationship, an analysis of the counterparty's integrity should be carried out, as well as verification of the signatory's authority.
7. Environmental responsibility
We are aware of our responsibility to society for environmental protection and adhere to the following principles in our work.
The media bot is attentive to its responsibilities in relation to environmental protection, work with hazardous materials, emissions of harmful substances into the air and water, and waste.
The company strives to efficiently use energy, water, raw materials and other resources, pay attention to combating climate change and energy efficiency issues.
We give preference (as far as possible) to the use of recycled, reused and recyclable materials, and encourage contractors to use the most environmentally friendly packaging materials.
8. Reporting
Data accounting
The media bot keeps complete and accurate records of the business and financial aspects of its activities. We must keep accurate, complete and timely records of all assets, debts, income and expenses, as well as Media Bot transactions. Misrepresentation of records and reports, as well as concealment of information, the accounting of which is necessary, is strictly prohibited and may result in dismissal. From the moment we receive or create records and reports, we must ensure that they are properly stored.
Audit
The Media Bot, like all public companies, has internal and external auditors whose task is to check financial statements and evaluate the internal control system. If you have received a request from the auditor to provide any information, you must understand that you are obliged to provide complete and reliable information without any distortion or manipulation.
9. Complaints and liability for violation of the rules
Filing and handling complaints
We have a confidential hotline that employees can use,
users, partners and clients for reporting violations of these rules. The hotline is open in the form of a special form through which you can send a request.
The line is organized by a third party independent of the Media Bot. Each request is assigned a number during registration, which can later be used to review the decision or provide additional information.
Reports received by the hotline are reviewed by the complaints review group, which includes members of the ethics committee.
Questions about the operation of the Media Bot services should be posted via feedback forms on the pages of these services.
Any form of harassment against those who in good faith seek help, provide information or otherwise assist in the investigation of any known or alleged violations is strictly prohibited in the Media Bot.
Bringing to justice
Each employee of the company is personally responsible for compliance with these rules (from disciplinary to criminal). The leaders of the violators, if they knew about the violation but did not do anything, also bear disciplinary responsibility.
Issues related to non-compliance with the principles of business corporate ethics of a Media bot by business partners of a Media Bot are addressed in the Supplier Code of Business Conduct.
Deviation from the rules
Deviations from these rules may be allowed in relation to specific situations and only in exceptional cases. Deviations from these rules may be allowed or prohibited at the discretion of the Media Bot and must be publicly disclosed if such a requirement is provided for by applicable law, regulation or rules.
10. Making changes and deviations from the rules
The Ethics Committee may amend these rules as necessary.
Employees must take part in trainings conducted in the Media Bot aimed at familiarizing themselves with the requirements of these rules. These trainings are conducted by the ethics committee annually or at other intervals.