on the Prevention of and Response to Corruption and Fraud
of the Non-Governmental Organisation “Ukrainian Security and Cooperation Centre”
1.1. The Policy on the Prevention of and Response to Corruption and Fraud of the non-governmental organisation “Ukrainian Security and Cooperation Centre” (hereinafter referred to as the “Policy”) defines the principles, rules and mechanisms for the prevention, detection and response to corruption, fraud, bribery and related violations in the activities of the non-governmental organisation “Ukrainian Security and Cooperation Centre” (hereinafter referred to as the “Organisation”).
1.2. The Organisation is guided in its activities by the principles of integrity, transparency and accountability, complies with the requirements of applicable Ukrainian legislation and international standards in the field of anti-corruption and response, categorically condemns any kinds of corruption, fraud and money laundering, and implements a system of measures aimed at the prevention, detection and minimisation of related risks in its activities.
1.3. No internal decisions, decisions of the General Assembly or orders of the Chair of the Board of the Organisation may be interpreted or applied as permission, grounds or justification for a breach of the requirements of applicable Ukrainian legislation.
1.4. The terms “corruption”, “fraud“, “unlawful benefit“, “conflict of interest“ and other terms and concepts used in this Policy shall be applied in the meanings defined by applicable Ukrainian legislation, in particular the Law of Ukraine “On the Prevention of Corruption“.
1.5. The Organisation undertakes to cooperate with organisations and partners that comply with the requirements of anti-corruption legislation and legislation on the prevention and combating of the legalisation (laundering) of proceeds of crime, terrorist financing and the financing of the proliferation of weapons of mass destruction.
1.6. The Organisation complies in its activities with the regime of economic and other restrictive measures (sanctions) established in accordance with Ukrainian legislation, as well as international sanctions, including those of the UN, EU, USA and other international partners whose decisions are recognised by Ukraine. The Organisation shall not enter into legal relations or cooperate with individuals or legal entities subject to sanctions.
1.7. The Chair of the Board of the Organisation bears personal responsibility for the establishment, implementation, maintenance and effectiveness of the anti-corruption compliance system within the Organisation, including timely response to identified violations.
2.1. This Policy applies to all members of the General Assembly, the Chair of the Board, staff, volunteers, contractors, partners, donors, interns and other persons acting on behalf of or in the interests of the Organisation.
2.2. Where a donor agreement provides for higher standards regarding the prevention of corruption and fraudulent actions, persons involved in the implementation of the relevant project or programme shall be required to comply with the conditions set out in such agreement.
2.3. This Policy applies to the Organisation’s activities on the territory of Ukraine, as well as in any other jurisdictions in which the Organisation carries out its activities, implements projects or cooperates with partners.
2.4. This Policy applies at any location and at any time, including working and non
3.1. he Organisation conducts its activities exclusively in accordance with Ukrainian legislation and applicable international standards.
3.2. In the event of any doubts as to the lawfulness of actions or decisions, the Organisation applies a more cautious approach and refrains from such actions until proper written legal clarification is obtained.
3.3. References to business customs, local practices, urgency, or the requirements or expectations of partners or donors cannot justify any departure from the requirements of legislation or this Policy.
3.4. The Organisation adheres to the principle of zero tolerance for corruption and fraud and expects the same approach from members of management bodies, staff, volunteers, contractors, partners and other persons acting on behalf of or in the interests of the Organisation.
3.5. It is prohibited to directly or indirectly demand, receive, offer, promise or provide any unlawful benefit for the purpose of influencing the decisions or actions of third parties.
3.6. So-called facilitation payments (payments to expedite or simplify procedures) are prohibited, regardless of their amount, local practice or form, including when disguised as hospitality or remuneration.
3.7. The Organisation does not permit the maintenance of double records, the falsification of documents or the concealment of the true purpose of payments.
3.8. The Organisation uses funds exclusively for the achievement of its statutory objectives and approved programmes and projects. All procurement is carried out transparently, on a justified basis and without bias.
3.9. Any attempt to circumvent the requirements of this Policy through third parties, agents, partners or donors shall be treated as a direct violation.
4.1. A conflict of interest is not in itself a corruption offence; however, it constitutes a risk to the reputation, integrity and effective functioning of the Organisation and is subject to mandatory identification and resolution.
4.2. Members of the General Assembly, members of the Organisation, the Chair of the Board, staff, volunteers, consultants and other persons involved are required to:
independently assess the existence of a real, potential or apparent conflict of interest;
promptly notify the Chair of the Board of the Organisation of the existence of such a conflict;
refrain from participating in actions or decision-making that may give rise to a conflict of interest.
4.3. A conflict of interest may arise, in particular, in the following circumstances:
family or close personal ties between persons in a subordinate relationship or who jointly make decisions;
decision-making regarding contractors in whom the person or members of their family have an interest;
receipt of gifts or other benefits from individuals or organisations in respect of whom decisions are being made;
combining activities within the Organisation with other activities that may affect impartiality.
4.4. Upon identification of a conflict of interest, the Organisation determines the manner of its resolution having regard to the circumstances, including by removing the person from the relevant decisions, restricting access to information, establishing additional controls, changing the person’s role, or terminating cooperation where resolution proves impossible.
4.5. Failure to report, delayed reporting or avoidance of the resolution of a conflict of interest constitutes a breach of the Organisation’s internal policies and may give grounds for the application of appropriate measures.
5.1. The primary measures for the prevention of corruption and fraud within the Organisation are:
familiarising members of the Organisation, staff, volunteers, partners and other persons with this Policy;
clear allocation of roles and responsibilities;
proper accounting of all income and expenditure;
confirmation of financial transactions with appropriate primary documents;
internal controls and, where necessary, audit;
restricted access to confidential information;
verification of partners and contractors within the Organisation’s capabilities;
compliance with internal rules regarding the conclusion of agreements.
5.2. The following are prohibited:
misuse of funds;
concealment or misrepresentation of financial information;
conclusion of fictitious agreements;
making payments without appropriate supporting documents.
5.3. The provision, offering or receipt of gifts is prohibited where they are intended or may create the impression of influencing decision-making, the performance of duties or the obtaining of an unlawful benefit.
5.4. The Organisation permits the giving and receiving of gifts only where they are appropriate, transparent, proportionate and compliant with Ukrainian legislation and this Policy.
5.5. The giving of gifts to officials of Ukraine, foreign states and international organisations is permitted exclusively within the framework of protocol or representative practice, subject to compliance with the value limits established by legislation and the absence of a conflict of interest.
5.6. Cash gifts are prohibited.
5.7. Upon receipt of an inappropriate or excessively valuable gift, the person concerned is required to decline or return it and to notify the Chair of the Board of the Organisation accordingly.
5.8. The Organisation may incur representative expenses within the approved budget, including for official meetings, meals, transport, accommodation, cultural events and promotional items bearing the Organisation’s branding.
5.9. Participation in representative events shall not be considered a gift.
5.10. Upon identification of possible violations, the Chair of the Board of the Organisation is required to take immediate response measures and ensure that the relevant situation is reviewed or investigated. A responsible person from among the members of the Organisation or its staff may be designated to conduct the review.
6.1. Every person who becomes aware of, or has reasonable grounds to suspect, corruption, fraud or other violations of this Policy in the activities of the Organisation must report this to the Organisation.
6.2. Reports may concern the actions or omissions of members of the General Assembly, members of the Board, the Chair of the Board, staff, volunteers, partners or contractors of the Organisation.
6.3. Reports may be submitted in written, electronic or oral form, including anonymously. Anonymous reports shall be considered provided that sufficient information is available for their verification.
6.4. All reports shall be considered objectively, confidentially and within a reasonable time.
6.5. Where necessary, the Organisation shall conduct an internal review or investigation and take appropriate response measures.
6.6. The Organisation supports and protects persons who in good faith report possible violations of this Policy (whistleblowers).
6.7. A whistleblower shall not be held liable for a good-faith report, even where the facts set out therein are not subsequently confirmed.
6.8. Any form of pressure, discrimination or persecution of whistleblowers is prohibited, including dismissal, demotion, deterioration of cooperation terms or termination of participation in the Organisation’s activities.
6.9. The Organisation ensures the confidentiality of information regarding the whistleblower and the content of the report, except in cases provided for by legislation.
6.10. The submission of knowingly false reports or the abuse of whistleblower rights is not permitted and may have consequences provided for by Ukrainian legislation.
6.11. The Organisation shall respond immediately to any instances of pressure on or persecution of whistleblowers and shall take measures to protect their rights.
7.1. Persons found to be in breach of the requirements of this Policy shall bear liability in accordance with Ukrainian legislation and the internal documents of the Organisation.
7.2. Depending on the nature of the violation, disciplinary, civil or other measures may be applied to the persons concerned, including termination of membership, employment, civil law or partnership relations with the Organisation.
7.3. Where violations contain elements of unlawful acts, the Organisation has the right to refer the matter to the competent authorities in accordance with the procedure established by Ukrainian legislation.
7.4. This Policy is binding on all members of the General Assembly, members of the Organisation, the Chair of the Board, staff, volunteers, partners and other persons involved in the activities of the Organisation.
7.5. In the event of changes to Ukrainian legislation, the provisions of this Policy shall apply to the extent that they do not conflict with applicable legislation.
