THE NAPC APPROVED THE METHODOLOGICAL RECOMMENDATIONS FOR THE PREPARATION AND IMPLEMENTATION OF ANTI-CORRUPTION PROGRAMS OF LEGAL ENTITIES

The National Agency for the Prevention of Corruption has approved the Methodological Recommendations for the preparation and implementation of anti-corruption programs of legal entities. Decision was made at the meeting.

The guidelines were developed with the assistance of the United Nations Development Program in Ukraine, the Organization for Economic Cooperation and Development and the International Organization for Standardization. Their text includes the best practices and examples that have been developed in recent years. Also, the Guidelines received positive feedback from the European Business Association and the Business Ombudsman's Council.

These Guidelines recommend the preparation of anti-corruption programs for legal entities. Thus, when developing an anti-corruption program, several factors should be taken into account, in particular:

• the size and structure of the legal entity;
• the location of the legal entity and the areas in which it operates or plans to work;
• scale and complexity of the activities of the legal entity, including the level of complexity of business processes;
• number of branches, representative offices, controlled by a legal entity;
• a list of all business partners of the legal entity;
• the nature and extent of the relationship of the legal entity with persons authorized to perform the functions of the state or local government;
• legislative, contractual or professional duties and obligations of a legal entity.

The «PRIKHODKO&PARTNERS» law firm, in the person of managing partner Andrey Prikhodko - a lawyer, an expert on the prevention of corruption, helps in the preparation of anti-corruption programs, such as:

• preparation of the anti-corruption program in accordance with the current legislation and accompany its approval to the NAPC;
• help identify possible corruption risks and create mechanisms to prevent corruption among employees;
• conduct briefings and explanations for employees on the prevention of corruption;
• to explain to the company's management about the methods and methods of their activities;
• to select and instruct the Commissioner for the implementation of the anti-corruption program;
• appeal against illegal actions of the NAPC to the leadership of the said structure or to the court;
• provide legal assistance and representation in case of a person's call to the NAPC;
• appeal against a protocol on an administrative-corruption offense or a court decision imposing a penalty.

Recall that anti-corruption programs are adopted in legal entities specified in part 2 of Article 62 of the Law of Ukraine «On the Prevention of Corruption».