1. We would recommend indicating in the section of the Companies’ Compliance Policy concerning Azerbaijan, as stated above under p. 3.2, the aggregate value of the multiple gifts that can be given during any 12 months period to any representative of the public sector performing his or her duties (powers) should not exceed fifty five (55) manats¹ (or USD$69.9).

As the official AZManat/USD exchange rate of the National Bank of Azerbaijan fluctuates, the Business Gifts Policy should indicate that these requrements should be considered before making any kind of gifts.

2. In defining the public sector for the purposes of identifying corrupt actions, a list of persons who are subject to corruption-related offences should bepresented. Accordingly, we would recommend providing such a list in the section of the Companies’ Compliance Policy concerning Azerbaijan.

Under the Article 2 of the Law “On Combating Corruption” the persons listed in section 2.2 above are subjects of corruption-related offences.