Client portal: Sign in
Service call center: 8 (800) 201 24 24
Business ethics

Good governance and ethical behaviour are fundamental principles of our work. Global Ports strictly complies with all relevant laws and regulatory requirements, while striving to maintain the highest standards of business ethics. We expect all of our employees, as well as contractors and suppliers, to share the Holding’s values and to act responsibly, honestly, and ethically.

The centrepiece of the Company’s ethical infrastructure is the Code of Conduct, which sets the framework for all aspects of our business practices. It describes the general principles of business ethics and acceptable standards of professional behaviour for all our directors, employees, and contractors. The document also covers human rights, anti-fraud and corruption, and conflict of interest principles.

The purpose of the Code is to clearly define our ethical standards and set clear expectations for employee behaviour and business activities, as well as to provide clear guidelines for decision-making in various work situations. To achieve this, we also regularly send employees up-to-date information on the Holding’s management policy and provide training to familiarise them with changes that affect corporate governance.

All employees are required to review the Code upon hiring. It is also available in electronic and printed form in the HR departments of all the Holding’s assets. Additional training programmes and sessions may be organised for employees in order to effectively inform and explain the provisions of the Code.

Employees and external parties are encouraged to report any suspected violations of the Code through various channels, including a dedicated hotline.

Human Rights

The main principles of Global Ports’ approach to protecting and ensuring the observance of human rights in all aspects of its activities are enshrined in the Human Rights Policy.

The Policy includes commitments to respect human rights that strictly comply with both Russian and international law. We also adhere to the UN Guiding Principles on Business and Human Rights and endeavour to integrate them into all facets of our operations. Our Policy sets minimum standards that must be met not only by our employees, but by all counterparties as well.

Global Ports respects and upholds the fundamental civil, political, economic, and social rights and freedoms of each and every person, treating them as an integral part of our corporate culture and daily practices.

The Company ensures equal opportunities for both job applicants when being selected for a position and full-time employees by providing decent working conditions, fair remuneration, and opportunities for further growth and development. The Holding strives to employ uniform principles and approaches to human resources management in all regions where it operates. It pays special attention to hiring employees with disabilities and creating decent and comfortable working conditions for them. A number of the Holding’s assets have collective bargaining agreements in place.

Global Ports consistently opposes any form of discrimination. As a matter of principle, we do not tolerate prejudice based on race, religion, political beliefs, marital status, age, gender, sexual orientation, or disability.

The Company has communication channels with employees (hotlines, contact via the corporate website, HR department, trade union organisation, and meetings with management) that any of them can use to report a conflict situation for further investigation. If a dispute arises within companies, it is fully investigated and, if the allegations are proven, the appropriate action is taken.

Cybersecurity

Information security is an integral part of sustainable development and responsible governance at Global Ports. As it digitalises its operational processes, the Company is making consistent efforts to protect its information infrastructure, as well as the data of customers, partners, and employees.

To minimise cyber risks and enhance the sustainability of the digital environment, the Company is implementing a set of technical and organisational measures that includes:

Modern information protection equipment Access rights differentiation system Multi-factor authentication and corporate password policy Protection of communication channels Regular software updates Management of vulnerabilities Incident monitoring and response

Global Ports has an Information Security Policy, as well as internal regulations that describe information protection requirements, the procedure for accessing information resources, and employee responsibilities. The documents are regularly updated to reflect changes in legislation and the technological environment.

To foster a sustainable information security culture among employees, the Company has introduced training and regular awareness programmes. Responsible behaviour in the digital environment is viewed as an important element of corporate ethics.

The secure Delo Space corporate messenger was put into operation as part of efforts to achieve digital independence and the Company’s technological sustainability strategy.

Given the rapidly growing popularity of various AI-based services, Global Ports has restrictions on the use of any third-party AI chatbots and chatbots that work with corporate data.

Responsible supply chain

Global Ports views sustainability as an integral part of doing business that is directly linked to corporate values and ethics. The Company seeks to build partnerships based on trust, transparency, and compliance with international standards in environmental protection, human rights, and corporate responsibility.

In 2022, the Holding drafted a Supplier Code of Conduct to inform current and potential counterparties about the basic principles that the Company observes in the course of its activities.

The Code reflects Global Ports’ commitment to building a sustainable supply chain in line with the UN Global Compact. According to these principles, a sustainable supply chain involves responsible interaction with suppliers and managing the environmental, social, and economic impacts of business decisions throughout the life cycle of goods and services.

Priority focuses for creating a responsible supply chain:

Environmental impact Waste reduction Human rights Enhancing the transparency of the supplier base Procurement Operational and product innovations Logistics and distribution Facility management

When concluding contracts, Global Ports asks its suppliers to confirm their acceptance of the principles enshrined in the Code:

Ethical principles Anti-corruption principles Occupational health and safety principles Human rights principles Environmental principles

In order to build a responsible and sustainable supply chain, Global Ports reserves the right to request information from suppliers to confirm their compliance with the principles set out in the Supplier Code of Conduct. At the same time, such requests must not contradict the norms of Federal Law No. 223-FZ. If a supplier refuses to provide the required information, the Company may decline further interaction with the supplier or not to enter into contractual relations at all.

When conducting tender procedures that are not subject to Federal Law No. 223-FZ and receiving equivalent offers from several suppliers, the Company may give preference to the candidate with the best sustainability performance.

The application of the Code is not yet mandatory in all procedures. However, in 2025, Global Ports plans to expand and strengthen ESG principles in its procurement activities, including updating the Supplier Code of Conduct and developing a questionnaire for the ESG assessment of suppliers and training materials for procurement personnel.