Code of Business Ethics & Conduct of Toloka

This Code of Business Ethics & Conduct (henceforth, the Code) applies to all employees of Toloka (henceforth, Toloka or the Company). These rules are based on the principles set out in applicable laws international standards, including the Universal Declaration of Human Rightsthe UN Guiding Principles on Business and Human Rightsthe ILO Conventionsthe UN Global Compact Principles.

Toloka is committed to the highest standards of business ethics. The Company also expects its employees to adhere to high ethical standards in carrying out business on behalf of Toloka.

Toloka adheres to the principle of zero tolerance of any violations of this Code.

This Code outlines the rules of behavior that Toloka employees must observe. Any violation of these rules may entail negative consequences including legal consequences for Toloka and for us — those who are subject to this Code.

We should read this Code together with our other detailed policies, guidelines adopted by Toloka. Each of us has the ultimate responsibility to ensure that we all comply with the laws, regulations, and ethical standards affecting Toloka business. Each of us is responsible for knowing and understanding the policies and guidelines contained in this Code, and for conducting themselves in compliance with Toloka policies and guidelines. Managers are responsible for ensuring that their team members understand and comply with these policies and guidelines.

It is important that our business partners also adhere to ethical conduct practices: a Supplier Code of Conduct has been developed for them.

1. We Work for Our Users 

Our core principle is to provide services to millions of internet users. It is critical that each of us follows this principle. This means, among other things, that the first thing a service manager should care about is the usability of their service. The Company expects that each of us feels responsible not just for their part of a project, but for the product as a whole. Take user feedback seriously. Don’t be shy to suggest improvements. If you detect a bug or an error in any Toloka service, please report it to the relevant manager.

Our success as a business largely depends on Toloka good reputation and on the trust of our users. This trust is a key value of Toloka and our brand. Remember that many users trust Toloka with their data. This data may include personal information (such as passport and payment details), correspondence with Toloka support specialists, information about the user’s friends and contacts, and other personal details. Our internal procedures restrict access to any nonpublic personal information of our users. This information is highly confidential and can be used only for its intended purpose. If you deal with such sensitive personal information, it is your duty to keep it confidential and make sure that no sensitive information is disclosed inappropriately or leaked.

2. Working at Toloka

Equal Opportunities

We believe that discrimination in any kind of work-related matters is unacceptable. Nationality, gender, race, political or religious views, sexual orientation, or anything else unrelated to professional skills and ability to perform one's duties is of no significance.

Toloka is an equal opportunity employer. We select candidates for a position based on their ability to solve tasks within their competence.

We are committed to respecting and upholding human rights. Using illegal child labor or forced labor at Toloka is unacceptable.

Relations with Colleagues

The same principles as those set forth above hold true for professional communications. Any form of harassment, threatening or abusive behavior, or rude remarks about someone’s gender, race, nationality, sexual orientation, political or religious views, etc are unacceptable in professional communications at Toloka.

All forms of sexual harassment - unwanted acts of a sexual nature against another person - are also prohibited.

Working Hours, Wages, Occupational Safety and Health Protection

Toloka complies with applicable local labor laws, including wages, working hours, and overtime.

The company respects employees' right to freedom of association and collective agreements.

We believe it is important for Toloka to be and remain a safe place to work, so we are committed to providing a safe work environment and monitoring employee exposure to harmful and hazardous work factors and take necessary measures to prevent emergencies.

Toloka monitors the proper condition of equipment, communicates health and safety rules to employees, and provides personal protective equipment if necessary.

The company undertakes to identify and eliminate the causes of incidents, keep proper records thereof and offer the necessary medical care to injured employees.

Toloka offices are arranged to be comfortable and safe for employees to work in and spend time after work. 

Toloka Property and Resources

The company provides us with the resources we need to work. All of the equipment is property of Toloka. The Company expects us to use Toloka resources with care. Although it is not forbidden to use the equipment for personal purposes, the Company expects us to take a reasonable approach and avoid overuse. Please also respect the effort of our colleagues who keep our offices clean and comfortable.

While you are free to bring guests to the office, remember that you take full responsibility to make sure that your guests don’t disturb anyone in the office and that no confidential information is leaked during or after the visit. Your guests must be accompanied at all times.

Intellectual Property

Our intellectual property includes, but is not limited to, Toloka logo, trademarks, patents, and software. These are important assets, and any use of them by our partners or for external events must be approved by our PR Department. If you suspect that someone is using Toloka intellectual property without authorization, please contact the Legal Department.

Toloka also respects the intellectual property of others. Unauthorized use of any copyrighted products may result in lawsuits and fines against both the team member charged with copyright infringement and Toloka, and may affect our reputation. If you need to use any content or software which is not owned by Toloka, please consult the Legal Department.

3. Compliance with Law

Compliance with applicable laws is the responsibility of each of us. All of us are expected to abide by all applicable laws, rules, and regulations in carrying out business on behalf of Toloka. Awareness of the law is important because some features of our services may be affected by legislation in specific countries. We must comply with all applicable import, export, and other trade-related laws and regulations in the countries where we operate. Toloka also requires compliance with trade and economic sanctions imposed by governments that are applicable to our companies, team members and activities.

We must be aware of the legislation of each country or territory where we operate that directly affects our professional duties, that is, the part of the legislation that regulates how the product or service we are in charge of can be offered in a specific country or territory. Please consult the Legal Department at the early stages of product development for guidance regarding the applicability or interpretation of any law, rule, or regulation.

Bribery is illegal in all countries in which Toloka operates. We strictly prohibit any form of bribery, including bribes, kickbacks, fraud, or illegal payments in order to obtain or retain business or regulatory approvals. We must follow Toloka policy related to giving and receiving any gifts or entertainment. We also prohibit facilitating payments, even when legal under local laws. Remember that local customs or common practices do not justify a crime.

Accordingly, we must not offer, give, solicit or receive any money or anything else of value for the purpose of (1) obtaining, retaining or directing business; or (2) bestowing or receiving any kind of favored treatment. The direct or indirect promise of a bribe is equated to bribery by the law. The decisions we make on behalf of Toloka in purchasing materials, supplies and services must be made with integrity and take into account competitive pricing, quality and performance. We must also refuse to accept bribes, kickbacks or any other illegal or improper payments, transfers or receipts.

The Company is committed to fair, honest and free competition and is committed to conducting business in full compliance with the antitrust and competition laws in force in the regions of its operations.

Securities Regulation

We must comply with applicable securities laws in all countries where we operate.

Selling or buying securities on the basis of material nonpublic (insider) information is illegal. Information is considered material insider information if it would reasonably be expected to affect a company’s stock price and has not been officially published on behalf of the company in press releases, data reports and surveys, the company’s blogs, or any other media. If you are unsure whether certain information is public, consult our Public Relations Department.

Likewise, in the course of your activities you may obtain material nonpublic information about publicly listed companies – for example, our business partners or potential acquisition targets. You should never trade in the securities of other public companies on the basis of material nonpublic information that you have obtained in the course of your duties.

4. Conflict of Interest

Each of us has certain obligations to Toloka. The Company expects, in particular, that in our professional activity we are guided, first and foremost, by Toloka interests and the interests of our users. A conflict of interest arises when personal interests (or your friends’, close relatives’, or partners’ interests) and Toloka interests collide.

In the context of business ethics, close relatives include parents, children, siblings, legal and de facto spouses, people you have a romantic relationship with, and any other people personally significant to you who may influence your work-related decisions.

If you are in doubt regarding whether a certain situation entails a conflict of interest, consider how an outside observer would see it. Can you describe the situation to your boss or colleagues? If the relationship or situation appeared in a newspaper or on a blog, how would it affect Toloka? All of us must avoid conflicts of interest and any situations that could be perceived as a conflict of interest.

Corporate Opportunities

You may not personally take for yourself (or your close relatives or friends) any business opportunities that you discover using Company resources, information or position. These opportunities are the sole and exclusive property of the Company. For example, if you learn of a potential business transaction in your role with Toloka, you cannot enter into that transaction yourself – that opportunity belongs to Toloka. It is your duty and responsibility to advance the Company’s legitimate interests when the opportunity to do so arises.

Work and Personal Life

You cannot use your position at Toloka to the benefit of your close relatives, friends, or partners – this would lead to a conflict of interest between the Company’s interests and interests of your relatives, friends and partners.

When working with close relatives, a conflict of interest takes place if:

one of the relatives is a subordinate of the other;

relatives are involved in the same business processes or both you and your relative are involved in making decisions regarding the same interrelated issues, while no other Toloka employees are involved in making these decisions.

Conflicts of interest should be avoided not only when working with close relatives, but also when working with anyone who has any kind of a relationship with you which might affect the impartiality and independence of your decisions.

For example, if your loved one is working as your subordinate, it is possible that you may provide him/her with more favorable terms of work and evaluate his/her results more favorably compared with other employees. Even if your decisions are not affected by your special attitude to this person, other employees may think that this is the case.

Combining Work at Toloka With Other Work

Each of us can work part-time or be engaged in personal business in our spare time. However, such activity should not conflict with your work at Toloka.

Working at Toloka alongside other professional activities may result in a conflict of interest if:
  • you work for or consult a competitor while working for Toloka;
  • you use or may use the results of your work or the work of your colleagues at Toloka, or you use or may use equipment, premises, or Toloka software to perform other work;
  • you use or may use your official position and authority at Toloka to obtain favorable terms for your other employer or your business;
  • you perform other work during your working hours at Toloka;
  • you use or may use Toloka confidential information to perform other work or to obtain favorable terms for another company or business that you own, participate in, or have an interest in.

Business Gifts and Hospitality

Exchanging business gifts, favors, or hospitality such as entertainment, trips, or meals with partners is one such situation that may create a conflict of interest or may be perceived as a conflict of interest.

Toloka expects that any gifts or hospitality that we receive or give will:
  • have a reasonable cost;
  • not create a conflict of interest;
  • be legal;
  • comply with local customs and business rules;
  • not make the recipient feel obligated;
  • not be a bribe or be potentially considered as a bribe, kickback or payoff;
  • not be extorted by the recipient.

We have introduced internal Gifts and Hospitality policies which stipulate thresholds and approval procedures that have to followed when giving and receiving gifts.

Receiving Gifts

We should not accept business gifts whose value exceeds our internal thresholds, or cash or any cash equivalents, including certificates, e-money cards, gift cards, etc, regardless of their nominal value.

You can accept standard products from partners, such as subscriptions or other marketing products (promo codes, certificates, discounts, etc.), within our internal thresholds, or if the gift is part of an approved promotion.

It is important to remember that when accepting such partner gifts, you should be guided not only by the acceptable value of the gift, but also by understanding whether you personally make business decisions regarding this partnership. For example, you can accept a discount from a partner if it applies to everyone at Toloka.

However, if such a gift is offered personally to a certain Toloka employee, accepting this gift will require approval in accordance with the Company’s procedures.

Inexpensive token gifts (non-monetary) are generally acceptable, such as flowers, fruit baskets, pens, or other promotional products. Invitations to business meals or events are also acceptable if they follow the above-stated principles, provided there is no indication that the invitation is intended to improperly influence your business decisions.

It is hard to define more precisely which type of gift is acceptable, therefore, we recommend taking a reasonable approach when you are offered a gift. For example, accepting a paper calendar is okay, but taking the latest iPhone or a luxury watch is not. When considering whether a group gift is acceptable, such as something presented to all employees of a department, estimate the value of the gift per person. You should also consider the risk if a partner offers to cover your holiday expenses or invites you to an event abroad with a promise to book a business class flight and a hotel suite for you.

Giving Gifts

We also try to follow the same rules when giving gifts or offering hospitality to our partners. We don’t want our partners to feel or look like they are exposed to a conflict of interest.

You can give business gifts that are not worth more than the acceptable gift value and that comply with Toloka regulations on business gifts. These include branded Toloka souvenirs, standard Toloka discounts, such as promo codes and other standard discount products, as well as Toloka subscriptions, as long as their annual cost does not exceed the acceptable gift value, or if the gift is given as a part of an approved promotion.

You cannot give money or cash equivalents (cash certificates, e-money cards, etc.) as a gift, regardless of their nominal value.

In addition to these rules, there might be local laws and regulations prohibiting or strictly restricting giving gifts or offering hospitality to government employees (such as employees of ministries, governmental departments, agencies or services). Please make sure that giving something to a government employee or inviting them somewhere at Toloka expense does not violate local laws.

Some types of gifts, including those that are not covered by these regulations, require prior approval in accordance with the Company’s procedures.

Other examples of conflict of interest include:
  • having an ownership interest or any other significant personal interest in a company that is either a competitor, vendor, customer or business partner of Toloka;
  • having a personal financial interest in a deal you are making on behalf of Toloka which might affect the business decisions you make;
  • using the Toloka brand name in your personal interests, for example in your own business.

Each of us should take a conflict of interest survey as required by Toloka. We should inform Toloka about any conflict of interest using the survey form.

5. Confidential Information


We have a lot of confidential information about our services and products, partners, users, product promotion strategies, proposed transactions, business plans and financial results prior to their public announcement. Since disclosing such information may cause serious damage to Toloka, each of us is forbidden to disclose such information prior to its public disclosure. We all sign a Non- Disclosure Agreement and agree to follow the Regulations on Commercial Secrets of Toloka before we start working at Toloka.

Even if you assume that your professional duties do not give you access to any confidential information, you are still very likely to learn about Toloka secrets. It might be an overheard conversation or a document you happened to find in a printer. Remember that you are obliged to keep confidential information secret (even from your colleagues who do not have access to such information) and use it only in your professional activities. You should not seek to obtain access to confidential information if your professional duties do not give you such access.

Information Security

Some important recommendations on how to keep sensitive information secret are specified in the requirements issued by the Information Security Department. Complying with these requirements is essential for protecting our confidential information. If you notice suspicious activity in our network, see signs of a malware infection, suspect that any of our services has been hacked, or know of any other information security violations, contact our Information Security Department.

Outside Communications

If you have to answer questions from third parties about Toloka, follow common sense, the recommendations of our Public Relations Department, and the Regulations on Commercial Secrets of Toloka. If you need to share our confidential information with a partner, do this only after they have signed a Non-Disclosure Agreement. Please make sure the NDA is signed before you disclose any sensitive information.

Do not attempt to gain our competitors’ confidential information when talking to colleagues from competitor companies. We respect our competitors and try to maintain honest competition. If you have friends or close relatives working for a Toloka competitor, please be cautious when discussing business with them.

When you interact with government authorities in the countries where we operate, follow the relevant recommendations of our GR Department. You may communicate with officials on behalf of Toloka only if you are authorized to do so. When communicating with officials, offer only Toloka official position. If you are not aware of Toloka official position, redirect the issue to the GR Department. Any inquiries from the mass media should be redirected to the PR Department.

6. Making Contracts

When making contracts on behalf of Toloka, we should always try to look for the best deal and pursue Toloka interests. However, while the cost of a deal is undoubtedly important, other factors such as the reputation of a potential business partner should not be underestimated.

At Toloka, we have internal procedures that define who is authorized to have access to Toloka funds or sign contracts on behalf of Toloka. You can find information about the authorized signatories in our internal documents.

We expect all those who are authorized to sign contracts and who have access to Toloka budget to be careful and considerate in spending our funds, and to sign contracts only after obtaining any appropriate internal approvals. If you sign a contract, make sure you understand and agree with every condition. Each contract must be approved in accordance with the approval procedure. Appropriate due diligence must be conducted on all vendors and contract signatories prior to Toloka engaging in business with them.

7. Environmental Responsibility

We are aware of our responsibility to society to protect the environment and adhere to the following principles in our work.

Toloka takes seriously its responsibilities regarding environmental protection, handling of hazardous materials, air and water emissions, and waste management. The company strives to use energy, water, raw materials and other resources in a sustainable manner, and to pay attention to climate change and energy efficiency.

It is our preference (whenever possible) to use recycled, reused and recyclable materials, and encourage contractors to use the most environmentally friendly packaging materials.

8. Accurate Company Records

Keeping Records

We must maintain complete and accurate business and financial records. We are required to record all assets, liabilities, revenues, expenses and business transactions of Toloka in a manner that is accurate, timely, and complete. Making false or misleading records or accounts or concealing information is strictly prohibited and will result in termination. Records and reports must be protected and stored appropriately from the moment they are received or created.


We have both internal and external auditors responsible for monitoring our financial accounting and evaluating our internal control system. If you receive an enquiry from an auditor, you must provide them with complete and accurate information free from any misrepresentation or manipulation.

9. Complaints and Consequences of Violations

Complaint Procedure

We offer a confidential hotline, through which Toloka employees, third parties, users, partners and clients can notify Toloka of any violation of this Сode. The hotline is accessible at Messages received to the hotline are reviewed by a review panel including the members of the Company’s Ethics Committee. 

Questions regarding the work of Toloka service may be submitted via the ‘Contact us’ link on the web page of the service.

Any form of retaliation against those who, in good faith, seek help, provide information, or otherwise assist in an investigation regarding any known or suspected violations, is strictly prohibited at Toloka.


Each company employee bears personal responsibility (ranging from disciplinary to criminal) for complying with these rules. Supervisors of violators, if they were aware of the violation but took no action, may also be subject to disciplinary action. 

Issues related to non-compliance with Toloka business ethics principles by Toloka business partners are covered in the Supplier Code of Conduct.


Waivers of this Code may be considered and granted on a case-by-case basis and only in extraordinary circumstances. Waivers may be granted or refused by Toloka in its sole discretion and, if required by applicable laws, regulations, or rules, must be promptly publicly disclosed.

10. Amendments

The Ethics Committee may review this Сode as required. All Toloka employees shall participate in trainings provided by Toloka, which are aimed at familiarizing them with this Code. Such training sessions are held annually or on a periodic basis as directed by the Ethics Committee.