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Golden Telecom, Inc., its subsidiaries and affiliates (collectively referred to as “Golden Telecom”) shall abide by the laws, rules and regulations of the countries where we do business and adhere to the highest standards in conducting business. In order our employees could understand and abide by these rules and standards, the Board of Directors of Golden Telecom, Inc. approved the Conduct Guidelines (“Guidelines”).

The Conduct Guidelines affirm Golden Telecom principles and guidelines regarding public disclosure of information, decisions approval process, trading in Golden Telecom securities, accurate recordkeeping, adherence to anti-corrupt legislation, conflicts of interests and other matters. The Guidelines are applicable to all of Golden Telecom employees, officers, directors and agents.

Compliance with the Guidelines is monitored and enforced by the Golden Telecom Compliance Officer, who reports regularly on the program’s implementation to the Board of Directors of Golden Telecom, Inc. View full text of the Conduct Guidelines

Many of the areas covered by the Guidelines are also governed by more detailed and specific policies. Among those areas are public disclosure of information, transactions involving Golden Telecom publicly traded securities, especially rules concerning insider trading and tipping, and the Golden Telecom Business Practices Training Program.

The Policy and Procedures on Insider Trading and Tipping contains a full summary of Golden Telecom’s policy regarding trading in Golden Telecom securities while in possession of material non-public information and disclosure of such information to others who may trade. The Policy and Procedures on Insider Trading and Tipping apply to Golden Telecom directors, offices and employees. Compliance with the policy is monitored by the Golden Telecom’s Compliance Officer.

The Business Practices Training Program highlights the United States Foreign Corrupt Practices Act (the “FCPA”) and anti-corruption legislation in the countries in which we operate. The Program is administered annually to each employee who is deemed to be in a position of responsibility that merits the importance of such training.