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This Anti-corruption program (hereinafter also referred to as the Program) the Joint Stock Company “Ukrainian Energy Machines” (hereinafter also referred to as the Company) declares that its employees, officials, manager and founders (participants) in their internal activities, as well as in legal relationships with business partners, bodies of state authorities, local self-government bodies, are guided by the principle of “zero tolerance” to any manifestation of corruption and will take all the measures for prevention envisaged by the legislation, identified th and fight against corruption and related actions (practices).
1.1. Anti-corruption program is a set of rules, standards and procedures for identifying, counteracting and preventing corruption in the activities of the Company
1.2. The program sets standards and requirements no lower than those stipulated by the Law of Ukraine “On the Prevention of Corruption” (hereinafter - the Law) and the Typical Anti-corruption program approved by the decision of the National Agency for the Prevention of Corruption.
1.3. The Anti-corruption Program is approved by the order of the General Director of the Company after its discussion with the Company's employees.
1.4. The text of the Program is in constant open access for employees, officials of the Company, as well as for its business partners.
2.1. Basic terms and definitions given in the Program:
3.1. The program is developed and implemented to support the anti-corruption strategy of the state by the Company, aimed at preventing corruption, improving corporate culture and management.
3.2. The Company sets itself the following goals:
3.2.1. Minimization of the risk of attracting officials of the Company, its employees and other persons acting on behalf of the Company in corruption activities.
3.2.2. Formation by shareholders, contractors, officials of the Company, its employees and other persons acting on behalf of the Company of the same understanding of the Company's approaches to non-acceptance of corruption in any forms and manifestations.
3.2.3. Generalization and explanation of the basic requirements of the anti-corruption legislation of Ukraine.
3.2.4. Establishment of a duty for the Company's officials, its employees and other persons acting on behalf of the Company to know and comply with the principles and requirements of this program, the key norms of anti-corruption legislation, as well as adequate procedures for preventing corruption.
3.3. The anti-corruption program is mandatory for all employees of the Company, including officials of all levels, the head, founders (participants).
3.4. Anti-corruption Program is also used by the Company in its legal relations with business partners, including public authorities and bodies of local self-government.
3.5. Implementation of measures for execution (implementation) of the Program within the limits of its authority is carried out by:
3.5.1. The founders (participants) of the Company (hereinafter – the founders (participants))
3.5.2. The head of the Company (hereinafter – the Head)
3.5.3. The official of the Company responsible for the implementation of the Program (hereinafter – also the Authorized Person) whose legal status is determined by the Law of Ukraine “On Prevention of Corruption” and this Program;
3.5.4. Officials of the Company of all levels and other employees of the Company (hereinafter – also employees).
4.1. Anti-corruption measures in the Company's activities include:
4.1.1. Anti-corruption standards and procedures in the activities of the Company;
4.1.2. Periodic assessment of corruption risks in the Company's activities.
4.2. The main anti-corruption standards and procedures of the Company are:
4.2.1. Familiarizing new employees with the content of the anti-corruption program, conducting training activities on preventing and combating corruption;
4.2.2. Anti-corruption check of business partners;
4.2.4. Regulations on mandatory compliance with the Anti-corruption Program;
4.2.5. Criteria for electing business partners of the Company;
4.2.6. Restriction on the Company's support of political parties, charitable activities;
4.2.7. The mechanism of reporting on the detection of signs of a violation of the Program, signs of corruption or corruption-related offenses, as well as the confidentiality of such messages and the protection of exposers;
4.2.8. The implementation by the Authorized Person (subordinated to him employees) of functions to prevent corruption;
4.2.9. The procedure for examining reports of exposers, including internal investigation and imposition of disciplinary sanctions;
4.2.10. Standards of professional ethics, duties and bans for employees of the Company;
4.2.11. Mechanisms for preventing and clearning of conflicts of interest;
4.2.12. Restrictions on the acceptance and delivery of gifts;
4.2.13. Supervision and monitoring compliance with the requirements of the Anti-corruption Program.
4.3. Periodic assessment of corruption risks in the Company's activities.
4.3.1. The Company conducts an internal assessment of corruption risks at least once a year in its activities. Corruption risk is the justified probability of occurrence of a corruption or corruption-related offense or violation of the requirements of the Anti-corruption Program.
4.3.2. The evaluation of corruption risks in the Company is carried out by the Commission for the Assessment of Corruption Risks (hereinafter - the Commission). The order of activities and composition of the Commission are approved by a Head.
The Commission is composed of the Authorized Person (the chairman of the commission), the heads of the Company's structural units, as well as other employees identified by the Head in coordination with the Authorized Person.
When assessing corruption risks on the initiative of the Authorized Person, other members of the Company, as well as independent experts or specialists, may be involved in the work of the Commission without including it.
The Authorized Person, in order to prevent conflicts of interest or bias of the work of the Commission, in the distribution of functions among its members, takes into account the range of their duties in the Company.
4.3.3. The purpose of the Commission is to prevent, identify and eliminate the corruption risks in the activities of the founders (participants), managers and employees of the Company.
4.3.4. Corruption risks in the Company's activity are subdivided into internal and external.
Internal corruption risks are identified in organizational, managerial, financial and business, personnel, legal procedures of the Company.
External corruption risks are identified in the activities of business partners, supervisory bodies, as well as bodies of state power, local self-government, with which the Company is in business relations.
4.3.5. Based on the results of identification of corruption risks, the Commission, in accordance with the procedure of its activities, carries out their definition and description, classification by categories and types.
4.3.6. Based on the results of the assessment of corruption risks in the Company's activities, the Commission prepares a written report, which is signed by its members.
The report is drawn up according to the form and structure determined in the procedure of the commission's activity.
The report on the results of the assessment of corruption risks is provided to the Company's Head and must contain:
The text of the report can be published on the Company's website.
4.3.7. If during the measures to assess corruption risks, the Authorized Person finds a violation of the Anti-corruption Program, commits a corrupt or corruption-related offense, he initiates to the Head of the issue of conducting an internal investigation in the manner recognized to the Program.
4.3.8. Based on the results of processing the report on the assessment of corruption risks, the founders (participants) take the necessary measures to prevent, identify and counteract corruption in the Company's activities, including by changing existing anti-corruption standards and procedures.
4.4. Anti-corruption standards and procedures in the activities of the Company.
4.4.1. In order to form an appropriate level of anti-corruption culture, the Authorized Person familiarize new employees, as well as other persons acting on behalf of the Company, with the provisions of the Law, the Anti-corruption Program and related documents.
4.4.2. Provisions regarding the mandatory compliance with the Anti-corruption Program may be included in the internal labor regulations of the Company, provisions on structural subdivisions, all labor contracts, as well as in contracts concluded by the Company with counterparties.
Approximate forms of anti-corruption clauses are developed by the Authorized Person, taking into account the specifics of the Company's activities.
4.4.3. Business partners of the Company are elected according to criteria that are based on transparency of activities, competition, quality of goods, works and services and reliability.
Anticorruption audit of partners in accordance with the requirements of the Anti-corruption Program, as well as standards for various areas of the Company's activities, are developed and approved by the Authorized Person.
4.4.4. The charitable activity of the Company must be carried out only in accordance with the legislation.
4.4.5. The implementation of the charitable activities of the Company is not allowed if:
Regulations on the procedure for maintaining the specified register is approved by the head on the proposal of the Authorized Person.
4.4.6 To notify employees of the Company of violations of the Anti-corruption Program, corruption or corruption-related offenses (hereinafter – also communications), the Authorized Person places relevant information on information stands at the premises of the Company and on his official website. Such information should contain:
The Authorized Person develops a standard form of the message, keeps records (register) of reports on violations of the Anti-corruption Program or signs of corruption or corruption-related offenses.
The procedure for maintaining the relevant register, the time limits and procedure for the consideration of messages by the Authorized Person shall be approved by the Head upon submission of the Authorized Person.
5.1. During the performance of their duties, employees of the Company are obliged to:
5.1.1. Strictly observe the generally accepted ethical standards of behavior;
5.1.2. Tolerate and respect the political views, ideological and religious beliefs of others, and also undertake not to use their powers in the interests of political parties and / or politicians;
5.1.3. Act objectively, in spite of personal interests and attitudes towards any persons, on their personal political, ideological, religious or other views or beliefs;
5.1.4. Conscientiously, competently, timely and responsibly perform its functional duties, decisions and instructions of bodies and officials to whom they are subordinated, accountable or controlled, and also prevent abuse and inefficient use of the Company's assets and property;
5.1.5. Do not disclose or otherwise use confidential information that has become known to them in connection with the performance of their functional duties, except in cases established by law.
5.1.6. In spite of personal interests, refrain from implementing decisions or orders of their leaders, if such instructions or decisions pose a threat to the rights protected by law, the freedoms or interests of individuals, legal entities, public or public interests or are contrary to law;
5.1.7. Refrain from exercising independently or through their subordinate employees to pay any expenses (money remuneration, loan, service, entertainment, leisure, transportation and other compensation) for public officials and their close relatives (or in their interests) in order to obtain or retain benefits for society in commercial activities.
5.2. The Head of the Company and the heads of the structural divisions of the Company form an ethical standard of irreconcilable attitude to any forms and manifestations of corruption, setting an example by their conduct and familiarizing themselves with the Anti-corruption Program of the Company's employees and counterparties.
5.3. Compliance by the Company's employees with the principles and requirements of this program is taken into account when forming a personnel reserve for promotion to higher positions, as well as for imposing disciplinary sanctions.
6.1. Founders (participants) Head and employees of the Company have the right to:
6.1.1. Submit proposals for improving the Anti-corruption Program;
6.1.2. To apply to the Authorized Person for consultations on implementation of the Anti-corruption Program and explanations of its provisions.
6.2. Founders (participants) the Head and employees of the Company are obliged:
6.2.1. Observe the relevant requirements of the law, the Anti-corruption Program and related internal documents, as well as comprehensively promote their implementation;
6.2.2. Fulfill its direct duties taking into account the interests of the Company;
6.2.3. To immediately inform the Authorized Person about cases of violation of the requirements of the Anti-corruption Program (or incidents of incitement to such actions), corrupt or corruption-related offenses committed by other employees of the Company or other individuals or entities with whom the Company is or is planning to be in business relations;
6.2.4. Immediately inform in the manner defined by the Anti-corruption Program about the occurrence of a real, potential conflict of interest;
6.2.5. Abstain from behavior that can be regarded as a readiness to commit a corruption offense related to the activities of the Company;
6.2.6. Do not commit or participate in the commission of corruption offenses related to the activities of the Company;
6.2.7. Provide the Authorized Person with adequate material and organizational working conditions;
6.2.8. Promote the Authorized Person's performance of the functions provided by the Law and the Anti-corruption Program;
6.2.9. Promptly respond to the written and oral appeals, proposals and recommendations of the Authorized Person, granted to him in the framework of the implementation of the Anti-corruption Program;
6.2.10. On the initiative of the Authorized Person to send inquiries to state authorities, local self-government bodies, enterprises, institutions and organizations regardless of the form of ownership in order to obtain from them the relevant information and materials necessary to fulfill the tasks assigned to the Authorized Person.
6.3. The Head of the Company and employees are prohibited to:
6.3.1. Use their official powers or their position and related opportunities to obtain undue benefits to themselves or others;
6.3.2. Use any property of the Company or its funds in private interests;
6.3.3. Demand or receive any material or non-material benefit (for oneself or for close relatives) in connection with the exercise of their official duties is not provided for by the labor or other agreement between them and the Company;
6.3.4. Organize, be an intermediary or personally perform any cash or non-cash payments or settlements with the Company's business partners, if such payments or settlements are not provided for by current legislation;
6.3.5. Influence, directly or indirectly, on the decision of the Company's employees to obtain any material or non-material benefit for themselves or for their close relatives is not provided for by the labor agreement or other agreement between them and the Company;
6.3.6. Take any actions that directly or indirectly incite the Company Head, other employees in violation of the requirements of the Law or the Anti-corruption Program.
6.4. After the release or other termination of cooperation with the Company, a person is prohibited from disclosing or using in any other way information (confidential) in his or her interests, which became known to him in connection with the performance of his powers, contractual obligations, except in cases provided for by law.
6.5. The demand, request, receipt of gifts for oneself or third parties from legal entities or individuals by the Head of the Company, his employees (directly or through other persons) in connection with the performance of his powers and related opportunities are not allowed.
The Head, employees can accept gifts that correspond to the generally accepted ideas of hospitality (for example, gifts in the form of souvenirs, food, reimbursement of transportation costs and hotel accommodation, etc.), unless the cost of such gifts exceeds one living wage for able-bodied persons, established on the day of accepting the gift, once, and the total value of such gifts received from one person (group of persons) during the year does not exceed two subsistence minimums, anovlennyh for able-bodied person on 1 January of the year in which the gifts are accepted.
The restrictions on the value of gifts provided for in this paragraph do not apply to gifts that:
6.6. The Head, employees of Company refrains from offering gifts to state employees, people's deputies of Ukraine, deputies of local councils, their close people, actual or potential business partners, their employees or representatives, and any other behavior that may be regarded as a willingness to commit an corruption offense , related to the activities of the Company.
Gifts may be permitted in cases where they correspond to generally accepted ideas of hospitality and their value does not exceed the sizes established by the Law and this Program.
7.1. Gifts that the Head of the Company, his deputies, heads of structural subdivisions, employees and other persons acting on behalf or by order of the Company, may confer on behalf of the Company to other persons in connection with their activities in the Company, as well as representative expenses for business hospitality, including management expenses, employees and other persons acting on behalf and by order of the Company, must meet following criteria:
7.1.1. Be directly related to legitimate aims of the Company or national holidays (Constitution Day, Independence Day, etc.) and apply them in accordance with financial condition of the Company;
7.1.2. Be substantiated and such, that value meets requirements stipulated in clause 6.5. of this Program;
7.1.3. Acquired and handed over in agreement with the Head of the Company;
7.1.4. Not be a covert remuneration for service, action, inaction, condoning, giving rights, making certain decision, committing assignment, obtaining permit, etc., or as attempt to influence recipient with another unlawful purpose;
7.1.5. Do not create reputational risk for the Company, management, employees and other persons acting on behalf and by order of the Company.
8.1. The Authorised Person of the Company is appointed by the Head in accordance with labor legislation and constituent documents of the Company.
8.2. The Authorised Person may be individual person who is capable in its business and moral qualities, professional and health level, comply with appropriate responsibilities.
8.3. It can not be appointed the Authorised Person (subordinate authorized employee) person in circumstances provided for in part three of Article 64 of the Law.
8.4. Incompatible with activities of the Authorised Person is work on positions specified in clause 1 of part one of Article 3 of the Law.
In case of incompatibility circumstances, the Authorised Person within two days from the date of such circumstances must notify the Head of the Company while applying for termination of employment contract on its own initiative.
8.5. The Authorised Person may be dismissed from office early in cases stipulated by part five of Article 64 of the Law.
On dismissal of persons from position of the Authorised Person the Head of the Company shall notify National Agency for Prevention of Corruption within two working days and provides immediate submission of a new candidate for mentioned position.
8.6. Main tasks of the Authorised Person are to prepare, provide implementation and control over implementation of measures to prevent, counteract and detect corruption in the Company.
The Authorised Person exercises his rights and duties directly. Before performing its functions, the Authorised Person may (with the consent of the Head) engage other members of the Company or 3 persons.
8.7. The Authorised Person's exercise of his functions in the Company is independent. Interference with activities of the Authorised Person on the part of founders (participants), the Head, employees of the Company, its business partners, as well as other persons, is prohibited.
It is prohibited to impose on the Authorised Person duties that do not belong to or exceed powers specified by the Law and this Program, or restrict exercise powers by him.
8.8. The Authorised Person for implementation of tasks entrusted to him is obliged:
8.8.1. Implement his functions objectively and impartially;
8.8.2. Organize preparation of internal documents of the Company on issues of formation and implementation of the Program;
8.8.3. Develop and submit for approval of the Head internal documents of the Company on issues provided by Anti-Corruption Program;
8.8.4. Ensure supervision, control and monitoring of compliance by the Head of the Company and employees of the Law and Anti-corruption Program;
8.8.5. Conduct assessment of results of implementation of actions provided by Anti-corruption program;
8.8.6. Ensure preparation of report on state of implementation of Anti-corruption Program;
8.8.7. Ensure cooperation with persons who report in good faith on possible violations of requirements of Anti-corruption Program, commission of corruption or corruption-related offenses;
8.8.8. Ensure preparation and submission to the Head of proposals of plan for conducting inspections of compliance with requirements of Anti-corruption Program;
8.8.9. Participate in conduct of inspections and internal investigations conducted under this Program;
8.8.10. Organize and take direct part in periodic assessment of corruption risks in activities of the Company;
8.8.11. Ensure establishment and maintenance of records and registers necessary for performance of duties assigned to him:
8.8.12. Organize and conduct anticorruption inspection of the Company's business partners;
8.8.13. Ensure confidentiality of information and protection of employees who reported violations of requirements of Anti-corruption Program, commission of corruption offenses or corruption-related offenses;
8.8.14. To provide founders (participants), the Head, employees of the Company with explanations and consultations related to application of Anti-corruption Program;
8.8.15. Provide information on measures taken by the Company to prevent corruption on the Company's website;
8.8.16. Participate in cooperation with public authorities, local self-government bodies, other legal entities, non-governmental and / or international organizations on issues of prevention of corruption;
8.8.17. Organize conducting of explanatory measures and measures for improvement of professional skills of the Company's employees on issues related to prevention of corruption;
8.8.18. Provide interaction and coordination between the structural units of the Company in preparation, ensuring of implementation and control over the implementation of measures regarding implementation of Anti-corruption Program.
8.9. The Authorised Person to perform tasks assigned to him has right to:
8.9.1. Receive written and oral explanations from the Head and employees of the Company on issues related to their authority (including during periodic assessment of corruption risks, anti-corruption inspections of business partners, inspections, internal investigations and expertise);
8.9.2. Receive from the Company's departments information and materials (certified copies of financial, accounting and legal documents, internal service correspondence) concerning activities of the Company, including documents related to implementation (or participation) of procurements of goods, works or services, etc.
If necessary, the Authorised Person shall have access to original documents, copies of which have been previously transmitted to him. In cases if making significant number of copies of documents is unsuitable, the Authorised Person may, on decision of the Head of division, may be provided with original copies of relevant documents to be returned to him within 10 business days from the date of completion of measure for which they were requested;
8.9.3. Receive drafts of financial, organizational and administrative documents, contracts for its verification for presence of corruption risks;
8.9.4. To receive access to warehouses, industrial premises of the Company, holding of control measures in them;
8.9.5. Obtain access to available at the Company electronic means of storage and processing of data and, if necessary, require execution of relevant data on certified paper medium;
8.9.6. To engage in performance of its functions with the consent of the Head other employees of the Company;
8.9.7. Initiate sending of inquiries to state authorities, local self-governments, enterprises, institutions, organizations of all forms of ownership for obtaining from them information and materials related to activities of the Company;
8.9.8. Participate in personnel recruitment procedures of the Company;
8.9.9. To exercise other rights stipulated by the Law, Program, employment contract and job description.
8.10 The Authorised Person shall prepare report on results of implementation of Anti-corruption Program (hereinafter also referred to as the Report) at least once a year, until 10 February of year following reporting year, which shall include information regarding:
8.10.1. Status of fulfillment of measures determined by the Program;
8.10.2. Results of implementation of measures determined by the Program;
8.10.3. Revealed violations of requirements of the Law, Anti-corruption Program and measures taken to eliminate such violations;
8.10.4. Number and results of inspections and internal investigations;
8.10.5. Facts of obstruction of proper performance by the Authorised Person of his functions, establishment of unreasonable restrictions for him, cases of interference with his activities by third parties;
8.10.6. Available suggestions and recommendations.
8.11. If necessary, the content of submitted Report is additionally discussed by the Authorised Person with the Head of the Company.
8.12. Annual Report may be posted in public place in paper and / or electronic form on the Company's website.
9.1. The Authorised Person oversees and continuously supervises compliance of the Head and employees of the Company with Program.
9.2. Supervision and control over observance of Anti-corruption program are carried out by the Authorised Person in following forms:
9.2.1. Consideration and response to reports of violations of requirements of Anti-corruption program, commission of corruption or corruption-related offenses;
9.2.2. Carry out scheduled and unscheduled inspections of activity of the Company's employees in relation to implementation (realization) of Anti-corruption program;
9.2.3. Conduct examination of organizational and regulatory, legal, production and financial documents, as well as its drafts.
9.3 If during course of overseeing or controlling compliance with Anti-corruption program the Authorised Person reveals signs of violation of the Program or signs of committing corruption or corruption-related offense, he initiates before the Head issue of internal investigation in manner prescribed by this Program.
10.1. Employees of the Company are guaranteed confidentiality regarding their Messages addressed to the Head of the Company or the Authorised Person about revealed signs of violations of Anti-corruption program, corruption or corruption-related offenses in the activities of other employees of the Company, etc.
10.2 Messages about revealed signs of violations of Anti-corruption Program, as well as reports of incitement of employees of the Company for commission of corruption or corruption-related offenses, may be filed orally or in writing, using communication channels specified in Program.
Messages may also be submitted by employees and officials of the Company's business partners.
The Head provides continuous work of these channels of communication and its protection against external interference and information leakage.
10.3 Submissions of knowingly false messages are not allowed.
10.4 Messages of employees of the Company about revealing signs of committing corrupt or corruptive offenses may be anonymous.
However, anonymous Message may be considered only if information contained therein relates to specific employee of the Company or business partners of the Company and contains factual data that can be verified.
10.5 Verification of information contained in message is carried out by the Authorised Person, and if message concerns actions of the Authorised Person himself - employee determined by the Head of the Company.
10.6 Any data that makes it possible to identify a person, who informed the Authorised Person of incitement to commit corruption or corruption-related offenses or to identify signs of violation of requirements of Anti-corruption Program, commission by employees or other persons of corruption or corruption-related offenses, belong to confidential information and protected in accordance with law.
The Authorised Person and persons involved in verification of information contained in message shall not be entitled to disclose it, except cases provided for by applicable law.
11.1 The Company provides conditions prescribed by law for protection of employees of the Company and other persons acting on behalf of the Company and providing assistance in preventing and combating corruption in the Company (hereinafter - the Accuser).
11.2. The Head, the Authorised Person, within limits of their competence, provide conditions for protection of persons who provide assistance in preventing, detecting and combating corruption in the Company.
11.3. Information about the Accuser can not be disclosed except in cases established by law. Information about accuser can be disclosed only with his consent, except cases established by law.
11.4 The Accuser can not be dismissed or compelled to be dismissed, brought to disciplinary responsibility or subjected to other negative measures of influence by management (transfer, re-certification, change of working conditions, refusal to appoint higher position, reduction of wages, etc.) or threat of such measures of influence in connection with Message submitted by him.
11.5 In the event of leakage of confidential information about the Accuser, the Head of the Company, the Authorised Person, upon application of such employee or on his own initiative, shall immediately take all measures to avoid occurrence of negative consequences for Accuser related to such disclosure.
11.6 In the event of threat to life, health and property of the Accuser or his relatives, in connection with reported violation of requirements of anti-corruption legislation, the Accuser may:
12.1. The Company places this Program in free access on official website, publicly declares rejection of corruption, and welcomes and encourages compliance with principles and requirements of this Anti-corruption Program by all contractors, its employees and other persons.
12.2. In order to form adequate level of anti-corruption culture with new employees introductory briefing for this Program and other normative acts related to it is held, and periodic informational events are held for current employees.
12.3. If there are questions regarding interpretation of certain provisions of Anti-corruption Program, founders (participants), the Head and employees of the Company may apply to the Authorised Person for oral or written explanation.
12.4 The essence of request for clarification or consultation is set forth directly by the Authorised Person(in designated by the Authorised Person days and hours of personal reception) or by sending a letter on his name ( business note of the Head of structural unit) or sending written application in arbitrary form to his e-mail address.
12.5 The Authorised Person provides oral clarification during personal reception or in writing - not later than within 10 working days from the date of receipt of letter or request on e-mail.
12.6. The Authorised Person may extend term of review of application, but not more than on 10 working days, about which in writing informs the person who requested clarification.
13.1. Improvement of qualifications of the Company's employees in field of prevention and detection of corruption is carried out in order to provide basic knowledge on issues of anti-corruption legislation, increasing level of ethical self-awareness and strict implementation of requirements of Anti-corruption Program, forming anticorruption culture, and raising intolerance to corruption.
13.2. Increasing of qualification can be carried out in form of measures for all employees of the Company, as well as individual measures for the Head, his deputies, heads of structural divisions of the Company.
Subject and form of activities (seminars, lectures, practical work, trainings, webinars, etc.) for improvement of professional skills are determined by the Authorised Person taking into account:
13.3 Registration of conducted measures for advanced training in field of prevention and detection of corruption, as well as registration of those present at events, is carried out by the Authorised Person.
14.1. In case of information indicating signs of violation of requirements of Anti-corruption Program, following measures are taken:
15.1. In the Company settlement of both real and potential conflicts of interest by the Head, his deputies, heads of structural divisions and other employees is carried out in accordance with requirements of Section 5 of the Law of Ukraine "On Prevention of Corruption".
16.1. In case of receipt of Message or direct discovery of signs of violation of Program by the Authorised Person, he shall notify the Head who takes measures provided for in c clause 2 of this section.
In case of receipt of message or revealing signs of violation of requirements of Anti-corruption Program by the Head or signs of committing corruption or corruption-related offense, the Authorised Person notifies founders (participants) who take measures provided for in clause 2 of this section.
In case of receipt of message or revealing facts about committing by the Authorised Person corruption or corruption-related offense, violation of requirements of Anti-corruption Program, the Head shall notify founders (participants) of the Company and take measures provided for in clause 2 of this section.
16.2. Under conditions provided for in clause 1 of this section, founders (participants), the Head must take following measures:
16.2.1. Within 3 days, initiate internal investigation to confirm or refute information about possible violation of the Anti-corruption Program or corruption or corruption-related offenses;
16.2.2. According to results of internal investigation apply disciplinary sanction to perpetrators if there are legitimate reasons for this;
16.2.3. According to results of internal investigation, identify ways to eliminate causes and consequences of violation, if any, and take measures to prevent such actions in future;
16.2.4. In case of revealing signs of corruption or corruption-related offenses for which administrative or criminal liability is stipulated, immediately inform specially authorized subjects in field of combating corruption.
16.3. Internal investigation is conducted only in cases where information provided or discovered is specific to individuals and contains factual data that can be verified.
Internal investigation is appointed by the Head and carried out by commission. Procedure for conducting internal investigations carried out in accordance with Anti-corruption Program is approved by the Head.
16.4 The Authorised Person is compulsory to be included in commission, except when the investigation is appointed for consequences of revealing facts or receiving information about commission by the Authorised Person corruption or corruption-related offense, violation of requirements of Anticorruption Program.
16.5 Term of investigation must not exceed 2 months.
Materials of internal investigations are kept in archives of the Authorised Person for at least 5 years.
16.6. In case if according to results of internal investigation the Authorised Person is subject to disciplinary action, National Agency for Prevention of Corruption shall be notified in writing within two days from the date of its imposition.
17.1. In connection with possible change in time of corruption risks and other factors affecting economic activities of the Company, the latter monitors implementation of adequate measures to prevent corruption, monitors its compliance, and, if necessary, reviews and improves them.
17.2. The Head of the Company ensures organization of feedback mechanisms and other internal processes aimed at supporting and continuous improvement of Anti-corruption Program.
17.3 Program can be viewed under results:
17.3.1. Report on assessment of corruption risks in activities of the Company;
17.3.2. Supervision and control over compliance with Anti-corruption Program, as well as evaluation of results of implementation of provided by it measures;
17.3.3. Analysis of practice of exercising by the Authorised Person his official duties;
17.3.4. Conducting by the Authorised Person questionnaire, discussion and consultations with employees, the Head, founders (participants) of the Company, as well as with business partners of the Company on improvement of Anti-corruption Program.
17.4 Initiator of change may be both the Authorised Person and founders (participants), the Head, employees of the Company.
17.5 Proposals for amending of Program shall be submitted to the Authorised Person who studies and systematize them. The Head, having received from the Authorised Person summary of proposals for amending Anti-corruption Program, initiates open discussion by employees of the enterprise.
In cases where founders (participants) or the Authorised Person insist on urgent introduction of certain changes to Anti-corruption Program, the Head shall initiate respective discussion within the shortest possible time, but not later than 10 days from the date of receipt of such proposals.
17.6 As a result of approval of submitted proposals, the Head shall approve relevant amendments to Anti-corruption Program by his order.
18.1. For commission of corruption or corruption-related offenses, persons referred to in the first part of Article 3 of the Law of Ukraine "On Prevention of Corruption" shall be subject to criminal, administrative, civil and disciplinary liability in manner prescribed by the Law.