Anti-Corruption Policy
Version of 4 October 2026.
Sky Digital Lab LLC (EDRPOU code 40906769, the AnyTrain service) does not tolerate corruption in any form. This Policy applies to the director, employees, contractors and anyone acting on behalf of AnyTrain, and follows the Law of Ukraine “On Prevention of Corruption” and the Criminal Code of Ukraine. This English text is a translation provided for convenience; the Ukrainian version prevails in case of discrepancy.
1. What is prohibited
1.1. Directly or through others promising, offering, giving, requesting or accepting an undue advantage — money, gifts, services, discounts, employment or any other benefit — in exchange for acting, not acting or making decisions.
1.2. Making payments to speed up or simplify procedures, or using company funds and property to finance actions that breach anti-corruption law.
1.3. Gifts and business hospitality are allowed only in ordinary amounts, openly and so that they do not influence decisions. Charity and sponsorship are transparent and may not serve as a hidden reward.
2. Conflicts of interest
2.1. Anyone acting on behalf of AnyTrain must report an actual or potential conflict of interest to the director no later than the next working day after becoming aware of it, and must not make decisions until it is resolved.
3. Business partners
3.1. We work with partners who comply with anti-corruption law, screen them against sanctions restrictions and include anti-corruption clauses in contracts.
3.2. We keep accurate records of transactions and retain documents on the conclusion and performance of contracts for at least three years after they end.
4. Reporting violations
4.1. Report suspected corruption or breaches of this Policy to info@anytrain.com.ua with the subject “Anti-corruption”. Reports may be anonymous.
4.2. We review reports within 10 working days, keep the reporter’s identity confidential and protect anyone reporting in good faith from any negative consequences.
5. Responsibility and review
5.1. Breach of this Policy is grounds for disciplinary action, termination of cooperation and notification of the competent authorities.
5.2. The Policy is reviewed as needed, and each new version is published with its date on this page.