Anti-corruption policy «INSIGHT SOLUTIONS» LLC

1. INTRODUCTION.

The core values of “INSIGHT SOLUTIONS” LLC (hereinafter referred to as the “Company”) are adherence to responsible and ethical business practices. The Company aims to promote and maintain the highest standards of ethics in all aspects of its business activities. Company’s reputation for upholding lawful business practices is paramount, and this Policy is designed to uphold these values. Therefore, the Company adheres to a policy of zero tolerance towards bribery and corruption and strives to act honestly and with integrity in all its business dealings and relationships, as well as to implement and enforce effective anti-bribery systems.

2. OBJECTIVES AND PURPOSES OF THE POLICY.

2.1. This Policy sets forth the Company’s position on any forms of bribery and corruption and provides guiding principles aimed at:

  • a) Ensuring compliance with anti-bribery laws, rules, and regulations in any country where the Company operates or where its business may be related;
  • b) Providing employees and individuals associated with the Company the opportunity to understand the risks associated with bribery and encouraging them to be vigilant and effectively identify, prevent, and report any breaches, whether by themselves or others;
  • c) Ensuring appropriate and secure reporting and communication channels and ensuring that any reported information is handled in a proper and effective manner; d) Creating and maintaining rigorous and effective frameworks for addressing any suspected cases of bribery or corruption.

2.2. This Policy applies to all permanent and temporary employees of the Company (including any of its agents, subsidiaries, or associated companies). It also applies to any individual or legal entity connected with the Company or performing functions on behalf of or for the Company, including but not limited to directors, temporary staff, contractors, consultants, seconded employees, agents, suppliers, and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles outlined in this Policy.

3. LEGAL OBLIGATIONS OF THE COMPANY AND COMPANY’S EMPLOYEES

3.1. The Policy is designed to ensure full compliance with uzbek legislation on Combating Corruption, as well as correspondent international acts. Since the Company conducts significant business outside the borders of Uzbekistan and continues to expand into emerging international markets, it is crucial that all employees understand the activities prohibited by the Company’s anti-bribery and anti-corruption regulations and ensure compliance with anti-bribery and anti-corruption laws in the countries where the Company operates. Each employee, officer, director, or agent is responsible for adhering to the uzbek legislation on Combating Corruption within their area of responsibility and for reporting any violations to their immediate supervisor.

3.2. All employees and associated persons of the Company are required to:

  • a) Comply with any anti-bribery and anti-corruption legislation applicable in any jurisdiction where they may conduct business;
  • b) Act honestly, responsibly, and with integrity;
  • c) Always uphold and adhere to the Company’s core values, acting ethically, professionally, and lawfully.

3.3. Bribery, including the offering or receiving of bribes, and intermediary activities in bribery are strictly prohibited. Under no circumstances should any funds be allocated, money be set aside, or accounts be created for the purpose of facilitating the payment, receipt, or offering of a bribe.

3.4. The Company recognizes that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or customary in another. However, all employees and associated persons are always required to adhere strictly to the guiding principles outlined in this Policy. If you have any doubts about whether something may be considered bribery or could constitute a breach of this Policy, consult with your immediate supervisor.

3.5. Providing business gifts to clients, customers, contractors, and suppliers is not prohibited, provided the following requirements are met:

  • a) The gift is not made with the intent to influence a third party to obtain or retain business or commercial advantage, or to reward for providing or retaining business or commercial advantage;
  • b) It complies with local laws;
  • c) It is given on behalf of the Company, not personally from the giver;
  • d) It does not include cash or cash equivalents (e.g., gift vouchers);
  • e) It is of an appropriate and reasonable type and value and is given at an appropriate time;
  • f) It is given openly, not secretly;
  • g) The gift is pre-approved by a Company’s director.

3.6. Therefore, it is prohibited to give, promise to give, or offer any reward, gift, or hospitality with the expectation or hope of receiving a business advantage; to reward for an already provided business advantage; or to accept any reward, gift, or hospitality from a third party known or suspected to be offering or providing anything with the expectation of gaining a business advantage for themselves.

3.7. Any payment or gift to a government and/or non-government official or other person to influence or expedite the performance of a routine governmental action or process, commonly known as a “facilitation payment,” is also strictly prohibited.

4. ANTITRUST AND COMPETITION

4.1. The Company prohibits agreements or actions that reduce competition without benefiting consumers and seeks to protect the competitive process so that consumers receive the benefits of competition.

4.2. The Company compete vigorously but fairly, based on the quality of our service – never through anti-competitive practices.

4.3. Employees of the Company must never engage in activities that could be seen as anti-competitive or monopolistic, including but not limited to:

  • a) Price Fixing: Agreeing with competitors on pricing of products, licensing fees, support contracts, or subscription rates;
  • b) Market Allocation: Dividing markets, customers, or regions with competitors;
  • c) Bid Rigging: Colluding with other companies to manipulate competitive bidding processes;
  • d) Tying or Bundling Products Unfairly: Forcing customers to buy one product or service as a condition for obtaining another;
  • e) Exclusionary Conduct: Refusing to allow interoperability with competitors’ software or systems without a legitimate technical or security reason;
  • f) Abuse of Dominant Position: Using a dominant market position to unfairly exclude competitors or limit competition, such as:
  • o Setting predatory pricing to undercut and eliminate competitors;
  • o Restricting access to essential APIs or development tools;
  • o Imposing restrictive terms in licensing agreements.
  • g) Boycott suppliers or customers;
  • h) Limit the production or sale of products or product lines.

These prohibited agreements should be equally avoided in discussions with clients, customers, suppliers, and the Company, as well as representatives of other companies. In addition, The Company must refrain from prohibited discussions with competitors (suppliers, other supplier’s partners, or other companies) about prices, costs, profits or profit margins, production volumes or bids, or quotes for a specific customer’s business.

4.4. Employees must exercise caution when interacting with competitors, particularly in:

  • a) Industry standard-setting organizations;
  • b) Open-source communities;
  • c) Conferences and trade events.

Do not share competitively sensitive information (such as roadmaps, pricing strategy, or customer lists) unless legally justified and cleared through the Legal Department.

5. IMPROPER PAYMENTS, MONEY LAUNDERING AND ECONOMIC BOYCOTTS

5.1. The Company strictly prohibits all forms of bribery, or improper payments, whether direct or indirect, to or from any government official, business partner, or third party. The above prohibition applies globally in any country to:

  • a) Government and public sector, which includes public utilities, higher education, public healthcare entities, and public international organizations and their employees or officials;
  • b) Political parties or candidates for political office;
  • c) Business entities partially or wholly owned or controlled by government interests (often referred to as state-owned enterprises) and their employees or officials;
  • d) Privately held commercial companies and their employees;
  • e) Any supplier’s employees;
  • f) Any other third party.

Prohibited Conduct includes:

  • g) Offering cash, gifts, or anything of value to influence a business decision;
  • h) Making facilitation payments (small unofficial payments) to speed up routine governmental actions;
  • i) Hiring or offering internships to relatives of government officials in exchange for favorable treatment;

5.2. The Company prohibits all forms of money laundering, which involves disguising, channeling unlawfully obtained money, or transforming such money into legitimate funds. Employees must be vigilant for:

  • a) Customers or partners requesting transactions through multiple shell entities or offshore accounts;
  • b) Large cash payments or unusual digital asset (e.g., cryptocurrency) transactions;
  • c) Attempts to obscure beneficial ownership or avoid documentation requirements;
  • d) Requests to split invoices or misstate transaction purposes.

5.3. The Company complies with all applicable international trade laws, including economic sanctions, embargoes, and anti-boycott regulations imposed by the U.S., EU, UN, and other jurisdictions. Prohibited activities include:

  • a) Doing business with entities or individuals on sanction lists (e.g., OFAC SDN list);
  • b) Participation in or supporting unauthorized foreign boycotts (e.g., agreeing not to do business with a country or company due to third-party pressure in violation of U.S. anti-boycott laws);
  • c) Failing to obtain required export licenses when dealing with restricted technologies or software.

5.4. All financial activities must be traceable, documented, and conducted in accordance with applicable Anti-Money Laundering laws, EU Anti-Money Laundering Directives, or relevant local laws of The Republic of Uzbekistan.

5.5. All business dealings must be transparent and properly recorded in the company’s books and records.

6. DEALING WITH GOVERNMENT

6.1. The Company is committed to conducting all interactions with government officials, agencies, and contractors with the highest standards of integrity, transparency, and compliance. This includes local, national, and international public sector bodies.

6.2. Employees must not:

  • a) Offer, promise, or authorize “anything of value” (e.g., cash, gifts, hospitality, or employment opportunities) to a government official to obtain or retain business;
  • b) Falsify documentation submitted to government entities, such as RFP responses, pricing structures, or compliance certifications;
  • c) Circumvent procurement rules or influence tender outcomes through improper means;
  • d) Attempt to gain access to non-public government information for competitive advantage (e.g., confidential bid specs or inside contacts).

6.3. When participating in government bids or tenders, employees must:

  • a) Follow all prescribed procurement procedures and submission requirements;
  • b) Maintain complete and accurate records of pricing, capabilities, and performance;
  • c) Ensure compliance with specific cybersecurity, data sovereignty, or local hosting requirements tied to public-sector IT contracts.

6.4. Any changes to contractual obligations, delays, or performance issues must be reported honestly and promptly to the appropriate government agency.

7. LOBBYING OF GOVERNMENT OFFICIALS

7.1. Lobbying is any activity that attempts to influence laws, regulations, policies, and rules. The Company is responsible for understanding when activities may legally be considered lobbying in a particular jurisdiction and for complying with all applicable laws of The Republic of Uzbekistan.

8. TRADE COMPLIANCE LAWS AND REGULATIONS

8.1. The Company is responsible for understanding how the global trade laws and regulations apply and for conforming to these laws to ensure no technology, data, information, program, and/or materials resulting from services (or direct product thereof) will be imported or exported, directly or indirectly, in violation of these laws, or will be used for any purpose prohibited by these laws and regulations.

9. REPORTING PROCEDURE

9.1. It is the contractual obligation and responsibility of all Company’s employees and associated persons to take all reasonable measures necessary to ensure compliance with this Policy, as well as to prevent, detect, and report any suspicions of bribery or corruption. An employee or associated person must immediately report to the Company’s management any information or suspicions they may have that any other employee or associated person plans to offer, promise, or give a bribe, or to request, agree to receive, or accept a bribe. For clarity, this includes reporting your own misconduct. The duty to prevent, detect, and report any instances of bribery and any potential risks lies not only with the Company’s directors but equally with all employees and associated persons.

9.2. The Company encourages all employees and associated persons to remain vigilant and report any illegal behavior, suspicions, or concerns quickly and without undue delay, so that investigations can proceed and appropriate action can be taken promptly. Confidentiality will be maintained during the investigation to the extent that it is practical and appropriate in the given circumstances. The Company is committed to taking appropriate action against bribery and corruption. This may include reporting the matter to the relevant external governmental department, regulatory authority, or police.

9.3. The Company will support anyone who has raised genuine concerns in good faith, even if they turn out to be incorrect, in accordance with this Policy. It also aims to ensure that no one suffers any negative treatment as a result of refusing to participate in bribery or corruption or because they have made a good-faith report of actual or potential bribery or corruption.

10. DOCUMENTATION

10.1. All invoices, receipts, bills, and other documents and records related to transactions with third parties must be prepared and maintained with strict accuracy and completeness. No invoices should be kept “off the books” to facilitate or conceal improper payments.

11. POLICY COMPLIANCE

11.1. The Company’s Director is primarily responsible for ensuring compliance with this Policy and will review its content regularly. The Director is also responsible for monitoring its effectiveness and will provide regular reports on this matter to the Company’s founders.

12. TRAINING

12.1. The Company’s Director will conduct training as needed for all employees to help them understand their duties and responsibilities in accordance with this Policy. The Company’s zero-tolerance approach to bribery will also be communicated to all business partners at the outset of business relationships and subsequently as necessary.

13. FINAL PROVISIONS

13.1. This Policy shall come into effect from the date of its approval by the Director and is mandatory for all employees of the Company.

13.2. All other terms not specified in this Policy will be governed by the current legislation of the Republic of Uzbekistan and the Company’s internal regulations.

13.3. The Director may amend this Policy by order, with such amendments coming into effect upon their approval.

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