Anti-Corruption
Program
Approved April 2026

SpecServis builds with
integrity and transparency

At SpecServis, we deliver infrastructure, facilities, and engineering solutions that serve people and communities. We build our corporate culture on the same principles — integrity, accountability, and zero tolerance for corruption in any form.

Our Anti-Corruption Program is more than a compliance document. It is a practical framework that guides the actions and decisions of everyone associated with our company — from senior management and employees to business partners and contractors.

Vladyslav Pashkov, Chief Executive Officer of SpecServis LLC personally leads these efforts and assumes responsibility for the implementation of this Program.

0
Tolerance for corruption
100%
Employee compliance
1999
Year established
27+
Years of trusted reputation

5 key principles of the program

The principles that shape our anti-corruption culture

Leadership from the Top

The Chief Executive Officer and managers at all levels demonstrate zero tolerance for corruption and establish the tone from the top by setting a daily example of ethical and responsible conduct.

Continuous Monitoring

The Anti-Corruption Compliance Officer performs regular monitoring, assesses corruption risks, and submits reports to management at least every six months.

Whistleblower Protection

Any employee, business partner, or contractor may report suspected violations anonymously. We guarantee confidentiality and legal protection for all individuals who report concerns in good faith.

Anti-Corruption Due Diligence

Before entering into any agreement, we assess the reputation and integrity of our business partners. An anti-corruption clause is a mandatory provision in every contract.

Training and Culture

All employees participate in mandatory annual training. New employees receive Anti-Corruption Program training during onboarding. Compliance knowledge and awareness are regularly assessed through testing.

The Program Applies to Everyone

The Anti-Corruption Program is mandatory for all participants in the Company’s activities

Founders and Management
Required to lead by example
Employees
All levels — from office to project site
Business Partners
Due diligence prior to contract execution
Contractors and Suppliers
Anti-corruption clauses in contracts
Public Authorities
Interaction strictly within the legal framework
Society
Transparent reporting and public oversight

What the Program Covers

A detailed overview of each section of the Anti-Corruption Program

Our Company strictly prohibits its employees, management, and representatives from:

  • Offering or accepting improper benefits from public officials, business partners, or clients
  • Making facilitation payments to accelerate administrative or formal procedures
  • Using Company resources for personal gain or corrupt purposes
  • Conducting any cash transactions outside the scope of contractual agreements

Every employee is required to act objectively and impartially, regardless of personal interests or external pressure. Confidential information must not be disclosed. If an employee receives an instruction that violates the law or infringes upon the rights of others, the employee is required to refuse to carry out such instruction and immediately report the matter to the Head of the Security Department.

The Company applies a risk-based approach to corruption prevention. At least once a year, the Anti-Corruption Compliance Officer conducts an assessment of corruption risks within the Company’s business processes. Based on the results of this assessment, a Risk Register is prepared and submitted for approval by the Company’s Chief Executive Officer.

The Company prohibits giving or accepting gifts intended to influence business decisions. Business hospitality is permitted only in accordance with generally accepted business standards and must not involve any hidden motives or improper influence.

During tenders, competitive selection procedures, and contract negotiations, situations may arise where multiple contractors compete for the same project, or where tender documentation and design requirements require additional clarification. In such cases, SpecServis operates exclusively through official channels. Written requests to clients, formal responses, and documented correspondence ensure that every stage of communication is properly recorded. This approach guarantees transparency throughout the selection process and prevents any informal arrangements during tendering or project design activities.

Every SpecServis employee — both office-based personnel and those working directly on project sites — undergoes a comprehensive screening process before employment. This process includes verification of the candidate’s documents, professional background, and business reputation, as well as checks for any involvement in corruption schemes or legal violations. Particular attention is paid to employees who interact directly with clients and contractors. This internal control system gives both us and our partners confidence that the SpecServis team consists of trusted professionals who uphold the highest standards of integrity.

Anti-Corruption Program of SpecServis LLC
Order No. 11/KM dated April 22, 2026 · Chief Executive Officer V.V. Pashkov