D MC “Fortum” in their activity trying adheres to the following ethical principles of receivable.

Section I. General provisions.

1.1 To observe the Ukrainian legislation, all regulatory legal acts and court decision, to effect honest and transparent activity.

1.2 To effect collection activity under the name, title or style not to mislead or to discourage clients, creditors, debtors or members of the public, or to associate with other non-existent organizations or people.

1.3 To respond all requests delivered to the Company in accordance with the Ukrainian active legislation.

1.4 To provide the relevant training and preparation for their employees, familiarizing them with principles of the said Code, and to demand that they fulfill their obligations in accordance with the Code. Besides, to provide long-term and proper training of employees taking into consideration the legislation in effect and best practice.

1.5  To state full business address, telephone number and e-mail in all outgoing correspondence.

1.6 To provide identification of members in all employees’ or agents’ contacts.

1.7 To provide conformity of debt collection procedures advanced Ethics standards by other companies, by studying them on an ongoing basis.

1.8 To provide observation of this Code and the Provisions of the Association by agents and contractors.

1.9 To respond to all justified requests of debtors, clients or their designated representatives regarding provision of information on their agreements, bills, state of ineptness and other information that may be provided to such persons without adverse effect for other parties beging subjects of information or related thereto, or of disclosure of such information may damage other persons.

Section II.   Confidentiality.

Article 2. Members of the Company shall keep in strict confidentiality any information obtained from a debtor, except when disclosure is allowed by the debtor or other parties designated or required by the law.

Section III. Review of complaints.

Article 3. Every member of the Association shall have the relevant methods of working with debtors’ or clients’ complaints, which shall include the following minimum procedure:

• Managerial level of complaints management.
• Timeframes for complaints management.
• Means of legal defense if a person, whose rights and interests are violated, is dissatisfied.

Such persons shall be made aware that one of the means of legal defense is transferring the complaint to the Association, if possible.

Article 4. Members of the Association shall manage complaints timely, responsibly, objectively without prejudice, and on the relevant managerial level.

Article 5. Procedures of members with respect to complaints submission shall be provided to a person, whose rights and interests are violated, or to his/her representative, if requested.

Article 6. If a complaint is submitted to the Association based on legal relations with a member of the Association, the Association will review the complaint in accordance with the promulgated complaint review procedure.

Section IV. Debt collection. Recommendations as to search of absconding debtors, and buyout of debt liabilities.

Article 7. Efficiency of debt collection methodology and the relevant procedures depends on circumstances that arose in the course of collection and, therefore, cannot be regulated in full scope. However, any member, who fails to completely observe the recommendations of the Association, will have to provide a justified explanation regarding the reasons for non-observance of recommendations in case that a complaint is delivered to the Association.

Article 8. Attempting at debt collection, in case of default in payment, members of the Association must:

8.1 not use collection procedures that may offend the debtor’s honor and dignity, and to refrain from any actions that are in conflict with the Code and may damage own business reputation of the company or reputation of the Association.

8.2 not use groundless pressure against a debtor in case of default in payment.

8.3 be careful and attentive when attempting at contacting the debtor by telephone, SMS, e-mail or during personal visit.

8.4 make sure that all attempted contacts with a debtor were within proper time (from 07:00 a.m. till 10:00 p.m.) at the relevant intervals.

8.5 in case  there were no other instructions, to accept all justified suggestions of debtors as to payment of the debt by installments, subject to objective reasons of the impossibility to pay the debt.

8.6 have the relevant approach and to work carefully with persons to have confirmed, or when it is obvious that such persons are incapacitated due to mental or psychic deficiencies.

8.7 offer maximum cooperation with a designated or elected Third party of a debtor.

8.8 induce debtors having financial difficulties to inform family members on their hardships to avoid conflict situations.

8.9 take into account all information provided regarding reasons for default in payment prior to determining whether it is necessary to force a person to pay the debt.

Article 9. Searching for absconding debtors, every member of the Association must:

9.1 not conceal information regarding his/her title.

9.2 take all the required steps to make sure that the searched debtor is the necessary person.

9.3 when detecting that the found person is not the debtor, to update all the required records accordingly.

9.4 when collecting debts and searching for absconding debtors, every member of the Association shall observe the principles of this Code and the Ukrainian active legislation.

Article 10. Working with clients, every member of the Association must:

10.1 provide honesty and transparency contacting with clients.

10.2 inform his/her clients on real cost of services rendered.

10.3 provide integrity of repaid money.

10.4 report to his/her clients according to existing arrangements.