Anti-Bribery & Anti-Corruption Policy

INTRODUCTORY STATEMENT

This Anti-Bribery & Anti-Corruption Policy (“Policy”) applies to the law firm “Leges Advokat”, a legal entity incorporated under the laws of the Republic of Uzbekistan and based in the city of Tashkent (“Leges”). Any reference to ‘we’, ‘our organization’ or ‘us’ in this Policy extends to each partner, lawyers, employees, agents or representatives, consultant and independent contractors acting on behalf of Leges (collectively referred to as “Leges Representatives”).

Leges is unique, both in its culture and its approach to law. Leges values its reputation and commitment to maintaining the highest level of ethical standards in the conduct of its business affairs, and to ensure that it, its lawyers, employees and others who may provide legal services on its behalf, act in compliance with all applicable laws of the Republic of Uzbekistan and prevailing internationally recognized practices. All laws and regulations, both domestic and international, prohibiting bribery or corruption in any form are implemented and strictly monitored in our legal practice.

We have a zero-tolerance attitude to any violation, whether it involves private individuals or public officials, and we will never offer, receive, support or solicit any bribery schemes (whether directly or indirectly), money laundering, kickback or other forms of improper payments.

Any breaches or alleged breaches of this Policy will be investigated by our compliance officer and will be directly reported to the Executive Committee of Leges to take the appropriate disciplinary actions.

ANTI-CORRUPTION LAWS

United Nations Convention against Corruption entered into force on 14 December 2005 (“UN Convention”);
Law of the Republic of Uzbekistan “On combating corruption” No. ZRU-419 dated 3 January 2017 (“Anti-Corruption Law”);
Decree of the Ministry of Justice, Department for Combating Tax, Currency Crimes and Money Laundering at the General Prosecutor’s Office of the Republic of Uzbekistan “On approval of the Internal Control Rules on Combating the Legalization of Proceeds from crime, financing of terrorism and the financing of proliferation of weapons of mass destruction in notary offices and law firms” 2020 dated 29 October 2009 (“Anti-Corruption Decree”);

UNDERSTANDING CORRUPTION, CONFLICT OF INTEREST & BRIBERY

Corruption – is an illegal use by a person of his official or business position in order to obtain material or non-material benefits in his personal interests or in the interests of other persons, as well as the illegal provision of such benefits.

Conflict of Interest – a situation in which personal interest (direct or indirect) affects or may affect the proper performance of a person's official or official duties and in which a conflict arises or may arise between personal interest and the rights and legitimate interests of citizens, organizations, society or the state.

Leges Representatives must not:

Make; or
Propose or promise to make
Solicit or authorize anyone to make; or
Intermediate in making

any benefits of any nature to any individual (who works either in the public or private sector) in order for such individual to proceed in violation of his/her duties, to an act or omission (with the purpose to obtain or retain business advantage); or
any payments/gift/anything of value either directly or indirectly to or for the benefit of any person, who is inducing, securing or rewarding the improper performance by any person of any function or activity, regardless of whether it was done to retain a business or competitive advantage.

The time, place and circumstances surrounding the bribery are irrelevant – we strongly condemn any form of association with the corruption, conflict of interest and bribery whether received knowingly or unknowingly. The following practices do not fall within the ambit of this Policy and are not aimed at restricting or prohibiting them, provided that they are appropriate, proportionate and properly recorded:

expediting the procedure in compliance with the relevant laws and regulations on the payment of increased official fees; and/or
providing information or resources to a responsible person or body to enhance the efficacy of the decision.

COMPLIANCE OFFICER: RIGHTS & FUNCTIONS

Pursuant to the Anti-Corruption Decree, the compliance officer of Leges carries out internal control and monitors compliance with this Policy and relevant laws in the following areas:

purchase and sale of real estate;
management of cash, securities or other property of the client;
managing bank, savings and securities accounts;
accumulation of funds for the creation, operation and management of legal entities;
creation, operation or management of legal entities, as well as purchase and sale of enterprises;
execution of executive orders;
and other areas in order to prevent any direct or indirect corruption and conflict of interest.

The compliance officer is empowered to take the following actions:

organize the implementation and introduction of internal control procedures and client due diligence;
transmit alerts to the state authority on suspicious transactions or actions of clients identified in the course of internal control procedures, as well as the execution of requests from the state authority for the provision of additional information;
monitor the organization of the internal control system and the elimination of shortcomings identified in the activities of the Leges Representatives;
demand from the Leges Representatives to provide necessary administrative or accounting information and/or documents necessary for the purposes of exercising internal control;
make copies of received documents, receive copies of files and other records stored in electronic databases, local area networks and autonomous computer systems of the organization for the purposes of internal control;
propose to the Executive Committee of Leges further measures with respect to suspicious notifiable transactions; and
other actions aimed at preventing or revealing corruption or a conflict of interest of any nature.

KEY-RISK AREAS

Examples of high-risk areas for corruption, money laundering and conflict of interest are outlined below:

individuals and business entities included in the List of subjects, which participate or are suspected of participating in terroristic activities and proliferation of weapons of mass destruction drawn up by the state authority, as well as entities controlled or related to such subjects;
individuals and legal entities permanently residing, located or registered in a state that is not involved in international cooperation in the field of combating money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, or in an offshore zone;
non-residents of the Republic of Uzbekistan;
organizations and individual entrepreneurs, the actual location of which does not correspond to the information specified in the constituent or registration documents, as well as those whose period of activity does not exceed one quarter of the financial year;
clients who carry out suspicious transactions on a systematic basis (more than twice in three consecutive months);
public officials, members of their families and persons close to public officials;
other persons whose operations cause reasonable suspicion of the compliance officer.

In the course of providing legal services and developing the nature of operations, the compliance officer should review the level of risk of working with the said clients.

PENALTIES FOR NON-COMPLIANCE

The Criminal Code of the Republic of Uzbekistan provides for the punishment of individuals and legal entities for up to 15 years of imprisonment and/or other sanctions. If Leges found itself to have taken part in the bribery or is found to lack adequate procedures for preventing the occurrence of bribery, the compliance officer or other Leges Representatives shall immediately inform the Executive Committee of Leges and the relevant state authority.