Global Anti-Corruption Compliance
Policy1.

Information about this Document

This Global Anti-Corruption Compliance Policy (the “Policy”) represents a part of commitment of group of companies Kaspersky Lab toconducting our business ethically and in compliance with all applicable laws wherever we operate.
This Policy focuses on anti-corruption laws, including the U.K. Bribery Act 2010 as amended (the “UKBA”), the anticorruption laws of
the Russian Federation, the U.S. Foreign Corrupt Practices Act of 1977 as amended (the “FCPA”), and other laws to which theCompany (as defined in clause 1.4 below) is subject.

1.1. Purpose
This Policy establishes the basic principles and requirements for compliance with theprovisions of Applicable Anti-Corruption Laws by the Company, the Employees of theCompany, and any Agents of the Company.
This Policy pursues the following goals:• Describing the Company’s prohibitions against bribery and corruption in all of its
business operations.
• Preventing any manifestations of corruption, both on behalf of and in regard to theCompany and/or its Employees; compliance with the requirements of applicable AntiCorruption Laws when the Company engages in its business activities.
• Reinforcing the Company’s commitment to conduct business globally with thehighest standards of honesty and integrity.
• Perfecting and developing the Company’s corporate culture, implementing the bestpractices and standards of responsible business conduct, including in the area of AntiCorruption Compliance.

11.2. Scope and Application

1.4. Definitions and Abbreviations

1.2.1

In case of any questions regarding application of this Policy please contact the Organizational Chief Compliance Manager (as defined in section 3.5 ofthis Policy) responsible Scopefor enforcement of this Policy. Contact details of the Chief Compliance Manager
can be found at web-site of Kaspersky Lab. You can also contact your local chief compliance manager.

1.2.2This Policy is used on the Company level, and applies to all of its structural
Area of Application subdivisions. In addition, the Policy operates in relation to the following entities: in the Context of • Kaspersky Labs Limited;
Organizational Structure• Kaspersky Lab UK Limited;

Term

Definition

Agents (Company Agents)

Agents, distributors, consultants, representatives, independent contractors, joint
venture partners, intermediaries, and other third parties engaged by the Company
that have the authority to represent the Company before other parties, including but
not limited to government entities.

Anti-Corruption Compliance

A system of measures, procedures and controls operating in the Company for purposesof compliance with Applicable Anti-Corruption Laws.

Anything of Value

The term “Anything of Value” is broad and can include any item of monetary value,
including, but not limited to, the following:• Cash or the equivalent (including gift cards);• Benefits and favors (such as special access to a government agency);• Performing services that would otherwise have to be paid for or purchased; • Gifts;• Contracts or other business opportunities awarded to a company in which a
Government Official has an ownership or other beneficial interest;• Favorable or steered contracts;• Employment opportunities, including those given to a family member or friend of aGovernment Official or representative of a commercialorganization, such as positions in joint ventures or consultancy opportunities;• Charitable donations;• Political contributions;• Medical, educational, or living expenses;• Travel, meals, lodging, shopping, or entertainment expenses; or • Investment
opportunities or stock options.

Applicable Anti-Corruption Laws

Company

Employees(Company Employees)

Any laws and regulations applicable to the Company dealing with combatting against
bribery (whether public or private), including the UKBA and other UK anti-corruption
laws, the FCPA and other US anti-corruption laws, anticorruption laws of the RussianFederation, the laws of the corresponding countries where the Company conducts its
activities.
The group of companies Kaspersky Lab as a whole, as well as all legal entities belonging tothis group individually (depending on the context).
Individuals engaged in long-term or temporary labor relationships with theCompany who have concluded a contract of a civil law character with the Company andcontractors hired by the Company with the engagement of outside organizations dealing
with the supply of personnel.

Improper Advantage

The term “Improper Advantage” covers any improper payment made in a business
context, such as (but not limited to) paying or giving Anything of Value to a Government
Official or private individual or entity, directly or indirectly, in order to:• Influence or prevent a governmental action, or any other action, such as the awardingof a contract, imposition of a tax or fine, or the cancellation of an existing contract orcontractual obligation;• Obtain a license, permit, or other authorization from a government entity or
Government Official that the Company is not otherwise entitled to;• Obtain confidential information about business opportunities, bids, or the activities ofcompetitors;• Influence the award of a contract;• Influence the termination of a contract that is disadvantageous to the Company; or• Secure any other Improper Advantage.

Governmental Entity

Any bodies of any national, regional, local or other government, including but not limited
to state ministries and offices, services, agencies and their structural subdivisions, as well
as all legal entities directly or indirectly controlled by the state as well as the judiciary. For
purposes of this Policy, the term comprises also political parties and internationalorganizations.

Government Official

Any employee or officer of a Governmental Entity, as well as any other individual or legal
entity acting at the proposal, request, or instruction, or in the interests of a Governmental
Entity.

• Subsidiary legal entities, including as appropriate affiliated entities and joint venturescontrolled by the Company, irrespective of their location;• All Employees of the Company, as defined in clause 1.4 of this Policy;• All Agents of the Company, as defined in clause 1.4 of this Policy, as necessary andappropriate in light of the respective Agent’s duties and responsibilities and as
manifested in the respective agency or other service agreements in place with such
Agent.

1.2.3
Applicability to Objects andActivities

This Policy applies to all types of activities undertaken by the Company.

1.2.4

This Policy constitutes the primary document of the Company on matters related Derivationby the sponsor of the present Policy.

to Anti-Corruption Compliance. Documents created on the basis of this Policy and Tailoring

and for purposes of implementing it should not contravene it, so long as they are not approved

1.3. Target Audience
The Policy applies to all of the Company’s Employees (as defined in clause 1.4 below), including the Company’s directors, officers and contractors hired through third-party staffing arrangements.
Every Employee is required to become familiar with, and abide by, this Policy.
All Employees have a personal responsibility and obligation to conduct the Company’s business activities ethically and in compliance with the law. Failure to do so may result in disciplinary action, up to and including dismissal.
Employees may also be subject to regulatory and criminal action, which may lead to fines, debarment from certain positions, reputational harm and other sanctions up to and including imprisonment.
This Policy applies to Agents and their personnel by extension, to the extent the requirements herein are manifested in agreements with such third-parties.

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2.

General Provisions

The Company is committed to maintaining the highest level of ethical standards in the conduct of its business.
The Company does not accept any forms of corruption on the part of private individuals or Government Officials. The Company
does not participate in any forms of unethical incentivizing or payments.
The Company does not engage in, nor does it accept any activity which does not comply with this Policy or with Applicable Anti-Corruption
Laws.
The Company, Company Employees, and Company Agents are forbidden to offer, promise, approve, engage or authorize, directly or
through an intermediary, in the transfer of Anything of Value to any Government Official or an agent or employee of a commercialorganization with the purpose of influencing his or her actions (or ensuring inaction) and/or obtaining improper commercial advantage.
The Company, Company Employees, and Company Agents are forbidden to give consent to the obtainment or to obtain, solicit or otherwise
receive, directly or through an intermediary, any payments in the form of money, securities, other property, render services of a propertyrelated nature, grant other property-related rights or any other valuables, as well as any financial or other benefit or advantage or Anythingof Value, if a condition for the obtainment of such payments, benefits or advantages is the commission of actions, the fulfillment of official
duties in the interests of the giving party, as well as if these payments, benefits or advantages constitute remuneration, direct or indirect,
for the fulfillment of such duties.

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The Company, Company Employees, and Company Agents are forbidden to act as intermediaries in public or private bribery, i.e., to directly
hand over bribes at the instruction of a bribe giver or bribe taker, or in some other way to assist in the achievement or realization ofagreement between them to receive and give a bribe.
This Policy constitutes the Company’s basic document in the area of Anti-Corruption Compliance; however, it is not invoked to implement
exhaustive rules of conduct for Employees and Agents of the Company. Other internal documents are currently in force in the Company,
and will be introduced in the future, on matters relating to Anti-Corruption Compliance to the extent that the Company shall deem to benecessary and sufficient for compliance with Applicable Anti-Corruption Laws. In the event of a conflict between this Policy and other
Company policies, Employees must apply the more restrictive policy or procedure. In such case, please notify the Chief ComplianceManager or your local compliance manager so that he or she can promptly address the conflict, advise you about any appropriate steps totake and, if necessary, update the relevant policy or procedure.
The Company’s management must through its conduct set a standard of ethical behavior and, by their personal example, form an
uncompromising attitude among the Employees and Agents of the Company to any forms and manifestations of corruption, whichmust become an inalienable part of the corporate culture and everyday business practices of the Company.

3. Basic Principles of the Company’s
Compliance

Anti-Corruption

3.1. Consistency in Application of the Policy

The Company consistently implements the rules and principles specified by this Policy
and other policies of the Company in the area of Anti-Corruption Compliance. The
Company propagates the principles of ethical business conduct and motivates theCompany Employees and Agents to comply with this Policy. In the event of a breach of
the rules of Anti-Corruption Compliance by Company Employees and Agents, theCompany shall apply the relevant liability measures to them.

3.2 Monitoring of Legislation and Best Practices
the Area of Compliance

The Chief Compliance Manager is directly subordinate to the Company’s General Director
and is endowed with the powers and resources necessary for effective implementation,
maintenance and improvement of the system of Anti-Corruption Compliance in the
Company.
In the event that any Employee of the Company has questions concerning the content of
this Policy, including questions of interpretation of any of its provisions, as well as doubts as
to the legality or ethical character of his or her actions, the application and realization of theprinciples of compliance indicated in this Policy, including questions related to theapplicability of such principles in this or that situation or business process of the Company,
the Employee shall be obligated to contact the Chief Compliance Manager or local
compliance manager for advice.

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The Company persistently follows all amendments to the normative requirements ofApplicable Anti-Corruption Laws and to the practice of applying it. Taking into
consideration the results of that monitoring, and based on the best practices of AntiCorruption Compliance, the Company takes measures to introduce the amendments into
its current policies.

In the event that an Agent of the Company has these questions, it is recommended to ask
the Chief Compliance Manager of the Company or local compliance manager forclarifications.

3.6. Reporting of the Chief Compliance Manager
On a regular basis, and also as needed, the Chief Compliance Manager shall report to theGeneral Director of the Company about the process of implementing and/ or improving thesystem of Anti-Corruption Compliance, about any violations uncovered during thereporting period, internal investigations undertaken, deficiencies of the internal
compliance controls and the measures taken in connection with this, as well as about thegeneral status of functioning and efficiency of the Anti-Corruption Compliance system in
the Company.

3.3. Periodic Risk Assessment
On a regular basis, the Company undertakes measures to bring to light and reduce
corruption-related risks, and also measures to assess the efficiency of the current system of
Anti-Corruption Compliance.
Taking into account the results of carrying out these measures, and in case of
appropriate necessity, the Company will amend existing policies or develop andintroduce additional policies. The measures undertaken must match the character ofthe risks discovered in a reasonable and proportional way.

Local compliance managers shall be subordinated through the functional line directly to theChief Compliance Manager to whom they shall report.

3.7. Forming and Upholding the Company’s Reputation

3.4. Informing and Training

The Company shall apply reasonable efforts to ensure that persons about whom it is
known that they are involved or have been involved in illegal activities will not be
admitted to managerial positions or allowed to join the Company’s management bodies.

A copy of this Policy will be given to every director, officer, and employee of the Company
and to contract workers engaged directly or through third-party staffing arrangements. All
updates to the Policy will be circulated internally. The Policy will also be made available via
the Company web-site and will be made available to all Company Agents.

The Company’s management bears liability for the maintenance and efficiency of thecorporate system of Anti-Corruption Compliance as a whole, and also for ensuring theimplementation and execution of controls and procedures of the Anti-Corruption
Compliance system in the areas of its functional competence.

Independently or with the engagement of outside specialists in the area of
AntiCorruption Compliance, the Company implements and supports a training programfor Company Employees and Agents in the principles and standards of Anti-Corruption
Compliance, works out a system of training sessions, and maintains training materials inan up-to-date condition.

Company Employees, irrespective of the position they hold, are personally liable forobservance of the principles and requirements of this Policy and the Applicable AntiCorruption Laws, as well as for the actions (inactions) of the persons subordinate to them
who violate these principles and requirements.

3.5. Appointment of a Responsible Employee
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The Company shall appoint an employee whose official duties consist of implementing
this Policy and the other policies of the Company on matters related to AntiCorruption Compliance (the “ Chief Compliance Manager”). The Company shall also
ensure that compliance managers are appointed at its country subsidiaries in order tointroduce and maintain Anti-Corruption Compliance systems at the local level.

4.

Specific Issues Related to Anti-Corruption Compliance54.1. Contractual Compliance Controls

In the cases designated by the Company’s policies, contracts entered into by the Company
with third parties must envisage the obligations of those parties to observe the Applicable
Anti-Corruption Laws (the anti-corruption clause), according to the wordings approved by
the Company. Furthermore, the contracts must specify the right of the Company to effectimmediate unilateral termination in the event of a breach of the obligations specified by
the anticorruption clause.
In the cases designated by the Company’s policies, contracts which theCompany enters into with third parties likewise must envisage the right of the Company tocarry out an audit of financial and other documentation pertaining to the implementation of
the relevant contract.

4.2. Due Diligence of Business Partners and Employees
The Company shall apply reasonable efforts to minimize risks associated with interaction
with any third parties, including business, labor and any other relationships with individuals
or legal entities.
For this purpose, the Company has developed and maintains procedures for inspection in
relation to Employees and business partners (legal entities and individuals), and withwhom the Company plans to enter into a contract. In addition, the Company carries out
periodical due diligence of business partners with which it has entered into long-term
contracts (lasting longer than one year).
The due diligence procedure in respect of the business partners and Employees has thefollowing goals:• assessment of the necessity of hiring a business partner, Employee, the purposes of thishiring in comparison to similar transactions of the Company;• assessment of the overall reputation of the Employee or a business partner, its owners
and key persons for compliance with the Applicable AntiCorruption Laws;• finding out whether any violations of Applicable Anti-Corruption Laws have beencommitted in the past;• establishing whether the potential Employee or a business partner has any connections
to Government Officials and Government Entities, which might influence obtainment by
the business partner or the Company of improper commercial advantages;• assessment of the impact of these connections on the legality of entering into thecontract with the business partner from the point of view of Applicable Anti-Corruption
Laws;• assessment of commercial reasonableness and arm’s-length basis for a proposedtransaction.
Any Anti-Corruption Compliance red flags raised during the course of the due diligence
review must be addressed to the satisfaction of the local compliance manager before
formally entering into, or continuing, the relationship.
The statements in this clause 4.2 of the Policy extend also to contractors undertransactions for merger, acquisition, or creation of joint ventures, and so forth. Moreover,also subject to due diligence are legal entities, ownership stakes or rights of control (direct
or indirect) of which the Company acquires as a result of the transaction.

4.3. Gifts and Hospitality Expenses
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The Company’s business decisions and those of its partners must be made objectively,
without influence by gifts or favors. A small, reasonably priced gift or gesture of gratitude
may sometimes be an appropriate way for business people to display respect for eachother. Nevertheless, regardless of value, the giving or receipt of a gift, meal,
entertainment, or other hospitality benefit must not be done with the intent to improperly
influence a Government Official or any other party doing business with the Company.

Any gifts and hospitality expenses of the Company (gifts which Employees and Agents of
the Company may give on behalf of and/or at the expense of the Company to otherindividuals or legal entities, or which Employees, in connection with their work at theCompany, may receive from other parties, as well as the corresponding hospitality
expenses) must be in conformity with the following criteria:
1. is not made with the intent to influence the recipient in order to obtain or retain any
improper business advantage for the Company or any other individual or entity, or as
an explicit or implicit exchange for favors or benefits, or for any other corrupt purpose;
2. must not be prohibited by Anti-Corruption Laws applicable to the Company andrecipient;
3. must not affect the capability of the recipient to make impartial and fair decisions inconnection with the official powers he or she has been entrusted with, nor must it
impose any moral obligation on the recipient;
4. must not constitute hidden remuneration for the obtainment of improper commercial
advantage, including any service, action, omission or decision, and likewise must not
represent an attempt to exert influence on the recipient with another illegal orunethical goal;
5. must be reasonably justified and not be a luxury item separately or jointly, if gifts or
payments are made to a person more than once;
6. must not create for the Company risks to its reputation in the event of disclosure of
information on such gifts or hospitality expenses;
7. must not contravene the principles and requirements of this Policy and other policiesof the Company in the area of Anti-Corruption Compliance; 8. must be offered andaccepted in a transparent manner and not be solicited;
9. must undergo the approval procedures established within the Company.
The indicated criteria shall also be applied to expenses on organization on behalf and/or at
the expense of the Company of events aimed at attraction, retention or development ofclients, as well as events related to communicating with the public, the mass media, andprofessional society.
Before the completion of any payment or donation of any gift in an amount exceeding(jointly during one-year period or separately) 100 USD to any third party, including to a
Government Official, on behalf and/or at the expense of the Company, the Employee
must contact the local compliance manager and provide detailed information about the
proposed gift or other paid expenses in order to receive confirmation about the legality
and admissibility of such payment or gift. Symbolic gifts, such as pens or calendars
bearing the Company’s logo, do not require the prior approval of the compliancemanager.
The compliance managers shall be entitled to block transfer of the gift or payment ofexpenses if he or she establishes that such actions do not comply with the criteria set
forth above, or create risks of violation of Applicable AntiCorruption Laws for theCompany.
It is not permitted to give gifts on behalf of the Company, Employees and Agents of theCompany to any third parties in the form of monetary funds, whether cash or not, as well as
any of their equivalents (for example, checks, gift cards, securities and so forth). Also, as a
general rule, it is never permissible to pay for air fare and travel for spouses, other family
members or other guests of Government Officials or any other third party.
Employees are entitled to accept small gifts and payment of hospitality expenses of modest
value from third parties with which the Employees interact in the course of work for theCompany, subject to the following conditions:• the acceptance of the gift or payment of hospitality expenses will not create for the
Employee a conflict of interests in regard to his or her official duties in the Company andwill not affect the performance thereof;• the Employee believes in good faith that the giver has no intention of affecting in some
way the performance by the Employee of his or her official duties.

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Employees must not solicit or request gifts. Employees are obligated to inform thecompliance manager if they receive any gifts or payment of expenses by third parties for an
amount greater than 100 USD (or the quality of that sum in local currency).

The Company ensures inspection of the reasonability and justification of payments or any
other provisions to third parties for the prevention and/or discovery of the violations
described above for purposes of minimizing the risks of involving the Company in corrupt
activities. All commercial relationships with third-party intermediaries must be approvedby the compliance manager, and all relationships must be put in the form of a writtenagreement.

4.4. Retaining Government Officials
It may be justified to retain a current or former Government Official as an Employee or abusiness partner of the Company. However, doing so must be handled with caution. Such
relationships must be structured so that they meet the requirements of the Applicable
Anti-Corruption Laws and other applicable laws of relevant jurisdictions, and must notcreate a conflict of interest for the Government Official. No such relationship may benegotiated or agreed to without the prior approval of the compliance manager.

4.8. Facilitating Payments
The Policy prohibits “facilitating payments,” i.e., unofficial payments provided in order toreceive or expedite (speed up) a routine government action, i.e., actions which are
ordinarily and commonly performed by Government Officials (e.g., processing
governmental papers, such as permits, visas, etc.).

4.5. Sponsorship and Corporate Social Responsibility
In accordance with this Policy and other implemented procedures, the Company does notfinance and does not participate in any other form in charitable and/ or sponsorship
activities for the purpose of receiving any illegal privileges or preferences in connection withbusiness activity.
All of the Company’s financial operations associated with sponsorship or charitable
activity are recorded in detail and in a trustworthy manner in the accounting records;
the project being realized undergo coordination in advance; the monitoring proceduresfor charitable contributions allow one to be convinced with a reasonable degree ofcertainty that the contributions made do not constitute a concealed form of bribery.

4.9. Books and Records
Employees or Agents are not allowed to conclude on behalf of the Company any
transactions with fraudulent intent or with knowledge of the fact that the transaction or
payment differs from the description in the documents confirming or justifying thetransaction or payment.

Before the Company or an Employee of the Company makes on behalf and/ or at theexpense of the Company any donation for an amount greater than 100 USD, it is necessary
to consult with the compliance manager, who is entitled to block payment after
performing the appropriate due diligence for compliance with Applicable Anti-Corruption
Laws.

For implementation of this prohibition, all financial operations, accounting postings andentries must be credibly recorded with a sufficient level of detail in the Company’s books
and records, and be documented and accessible for inspection.
Any payments to the third-party Agents should be made to bank accounts held by such
Agent in the country in which the relevant goods or services were provided or thecountry where the Agent is registered. Any expenses for which reimbursement isrequested by an Employee or Agent of the Company, as well as any expenses of theCompany performed using cash resources, must be confirmed in documentary form
using proper primary documentation, including original receipts, invoices or otherrelevant documents. Any requests for expense reimbursements must be approved by
the supervisor of the Employee requesting payment.

4.6. Financing of Political Activity
The Company does not finance and does not support or encourage in any other way
political parties or members thereof, including candidates for political positions, theirelection campaigns or political events, nor any political organizations or movements.

4.7. Payments through Intermediaries
Favor of Third Parties

4.10. Audit and Control

in8

On a regular basis, the Company carries out internal and external audits of its financial andbusiness activities, and also carries out ongoing control over the completeness and accuracy

9of the recording of all business operations in the books and records and observance of therequirements of applicable legislation and the Company’s internal normative documents,
including the principles and requirements established by this Policy.

The Company, its Employees and Agents are forbidden to engage any third parties for thecommission of any actions that contravene the principles and requirements of this Policyor the standards of Applicable Anti-Corruption Laws. Such actions by third parties may
expose the Company even if they have no actual knowledge or awareness.
The Company, its Employees and Agents are forbidden to make payments in favor of third
parties, if there exists suspicion that all or part of this payment will be used to bribe aGovernment Official or an agent or employee of a commercial organization.

As part of the internal control procedures at the Company, inspections are carried out
into the discipline of implementing the established procedure for performance ofbusiness processes, including inspection into the legality of the operations undertaken
involving the Company’s assets and their economic justification, the advisability of
expenses, including for confirmation by primary accounting documents and conformity
with the requirements of this Policy.

Within the limits of its powers, the Company shall undertake to ensure the protection of
Employees who have conscientiously reported a violation or suspicion of a violation of theprovisions of this Policy and/or Applicable AntiCorruption Laws from persecution or any
other form of discrimination on the part of the party in relation to whom the report was
made.

4.11. Informing about Violations
Every Employee and Agent of the Company who has become aware of facts (or of signs
pointing to them) regarding a violation or inclination to violate the provisions of this Policy
and/or Applicable Anti-Corruption Laws by Employees or Agents of the Company, as well
as by third parties, must inform about it in any of the following ways:
1. by informing the direct supervisor or, if such communication concerns the actions of thedirect supervisor, to a higher ranking supervisor,
2. via the Company's "Hotline" or by sending a message directly to this address:
nocorrupt@kaspersky.com, which can be done anonymously as well (from an outsideemail address),
3. by informing the Chief Compliance Manager of the Company or a local compliancemanage105.

Liability

Inasmuch as the Company may be held liable for the participation of Employees and Agents of the Company and other parties associatedwith it in corrupt activities, for each justified suspicion or established instance of corruption, internal investigations will be undertaken inaccordance with the Company’s rules establishing the procedure for carrying out such an investigation in a context permitted by applicablelegislation.
Parties guilty of breaching this Policy and of Applicable Anti-Corruption Laws may face disciplinary, administrative, civil law or criminal
liability at the initiative of the Company, the law enforcement authorities, or other entities in the procedure and on the grounds specified
by the Company’s Charter, internal procedures, and also in the appropriate cases and given sufficient grounds, in accordance with
Applicable Anti-Corruption Laws and other applicable laws and regulations.

In addition, the Company guarantees that none of its Employees will be held responsible (bybeing dismissed, demoted, deprived of a bonus, and so forth) by the Company if the
Employee reported the presumed corruption in good faith, or if the Employee refused togive or take a bribe or render mediation in acts of bribery, including if such refusal results inforegone profit for the Company, or no commercial or competitive advantages were gained.
Retaliation may result in disciplinary action up to and including termination.
The Company’s guarantees to refuse to hold Employees accountable do not extend to guilty
Employees, nor to cases when an internal investigation proves that the report in question
was deliberately false, or constituted perjury or libel.

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