Company policy in the area of corruption prevention

1. Introduction
This Corruption Prevention Policy (hereinafter referred to as the Policy) is developed in accordance with international standards and the legislation of the Republic of Armenia and is binding for all employees of Gulian Digital LLC, as well as for our partners and counterparties.
2. Purpose of the Policy
The purpose of this Policy is to prevent corruption and corrupt practices in all their manifestations and forms, strengthen the Company's business reputation and create an effective anti-corruption system.
3. basic principles

• Legitimacy: The activities of the company and all its employees are carried out strictly within the framework of the current legislation of the Republic of Armenia and international law.
• The unacceptability of corruption: The Company categorically rejects any form or manifestation of corruption.
• Openness and transparency: The Company adheres to the principles of openness and transparency in its activities.
• Ответственность: Each employee of the Company is personally responsible for complying with the requirements of this Policy.

4. key commitments

• Preventing conflicts of interest: Employees have a duty to avoid any situation that could give rise to a conflict of interest.
• Refusal of gifts and hospitality: Employees are prohibited from accepting gifts or favors that may affect their objectivity and independence.
• Integrity and fairness: Employees must act with integrity and fairness in all business transactions and relationships.
• Confidentiality: Employees are obliged to respect the confidentiality of information obtained in the course of their duties.

5. Measures of liability
Violations of the provisions of this Policy are subject to disciplinary action, up to and including termination of employment and referral to law enforcement authorities.
6. Control and monitoring procedures
The Company undertakes to conduct regular monitoring and audits to verify compliance with this Policy and to provide for measures to improve the anti-corruption system.
7. Feedback
Anonymous communication channels have been established for reporting corruption or violations of the Policy, including a hotline at +374-91-114-331 and a special e-mail address anticorruption@gulian.digital .
8. Conclusion
Each employee is familiarized with this Policy upon employment and agrees to abide by it. This Policy shall remain in effect indefinitely until it is formally revised or rescinded.

Effective Date: 29/03/2023
Director General of Gulian Digital LLC _________ Gulian A. Г.