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The entire process of humanitarian demining should be monitored by one – body, this will prevent corruption in the – industry Volodymyr Bayda

02.04.2026

In Ukraine, it is necessary to strengthen the vertical of humanitarian demining in order to avoid possible corruption on the part of operators. The lack of understanding and coordination of all efforts in a single vertical – is a systemic problem that the Center for Humanitarian Demining constantly points out and confirms the thorough research they conducted last year at the Tony Blair Institute.    

This was said by the director of the Center for Humanitarian Demining, Volodymyr Bayda.  

According to him, currently in Ukraine, about 13 state institutions are involved in the organization of the field of mine action, which complicates the process of quality control of operators.  

The center managed to save hundreds of millions of hryvnias of the state budget by successfully implementing the state program of compensation to farmers for demining. This made it possible to reduce the cost of demining tenfold – from $3 to 12 cents per square meter. At the same time, it is imperative to modernize legislation and provide control functions to prevent abuses during demining.  

“We have repeatedly appealed to the state authorities with the initiative to make the necessary legislative changes. It is possible to ensure a fully transparent process of humanitarian demining – from the identification of the contaminated site, its cleaning to the issuance of a – certificate, when one vertical” will be monitored, – said the director of the Center.  

Volodymyr Bayda noted that all the mechanisms used by the Center in the field of humanitarian demining have repeatedly passed all the necessary inspections by bodies in the field of control over the use of budget funds – inspections by law enforcement agencies, the accounting chamber, and the state audit service.  

“The Center must implement the quality control function provided to it by the Law.  In the staff, we have created a unit that can deal with quality control and undergo the procedure of accreditation of specialists. We hope that in a few months we will be able to strengthen the industry with independent quality control of the operators' work. So that we can finally go and check the work in the fields, – he added.  

Volodymyr Bayda noted that the consequence of the lack of a function of independent control, coordination and understanding of humanitarian demining processes on the part of all participants in the – process is criminal proceedings against individual operators.  

The Humanitarian Demining Centre has, since the beginning of its activities, the launching of the compensation programme, as well as since the opening of criminal proceedings, provided all the documents necessary for a comprehensive investigation and cooperated with law enforcement agencies to help establish objectively all the circumstances within the framework of criminal proceedings.  

We also call on humanitarian demining operators, law enforcement and regulatory authorities to comprehensively cover any episodes and cases in the field of humanitarian demining in order to prevent citizens from neglecting mine safety rules. Individual manifestations of dishonesty should not affect dozens of operators who faithfully and legally perform the assigned tasks.  

 

              APPROVED

            Order of the Humanitarian Center

demining

                                       30«December 2024. № 59

 Anti-corruption policy  

Center for humanitarian demining    

1. General provisions

1.1.  The Humanitarian Demining Center (hereinafter – Center), in order to implement the measures provided for by law to prevent and combat corruption, approves the Center's Anti-Corruption Policy (hereinafter – Policy).    

1.2. With this Policy, the Center declares that in its activities, including legal relations with business partners, officials, state authorities, local self-government bodies, it is guided by the principle of zero tolerance for any manifestations of corruption and will take all measures provided for by law to prevent and counter corruption and any related actions (corruption practices).

1.3. In this Policy, the following terms are used in the following meanings:

charitable activity - voluntary personal and/or property assistance from the Center, which is aimed at promoting the legitimate interests of recipients of charitable assistance in the areas of charitable activity defined by law;

business hospitality - representative events (for example, business breakfasts, lunches, dinners, buffets, tastings, other events (conferences, cultural and sporting events)), reimbursement of travel expenses, accommodation, other types of expenses carried out by the Center or in relation to the Center for the purpose of establishing or establishing business relations or for other purposes related to the Center's activities;

business relations - relations between the Centre and a business partner related to the Centre's business, professional or economic activities, arising from a contract or by concluding memoranda, agreements of intent, joint protocols, etc. (except for Ukrainian State bodies, international organizations of which Ukraine is a member, international technical assistance projects that have undergone the relevant State registration) to achieve common interests and provide for the duration of existence after their establishment;

business partner – any legal, natural or entrepreneurial person with whom the Center intends to establish a contractual or other business relationship (potential business partner) or already has such contractual or other business relationship (available business partner);

incentive payments - informal and illegal payments to officials in order to facilitate/accelerate/simplify or, in certain cases, properly implement the procedures established by law, which the Center has the legal right to receive without making such payments;

corruption risk - the probability of committing a corruption or corruption-related offense, other violation Law, which will negatively affect the Center's activities and/or business reputation;

unlawful benefit - money or other property, advantages, benefits, services, intangible assets, any other benefits of an intangible or non-monetary nature that are offered, promised, provided or received without legal grounds;

zero tolerance for corruption - absolute intolerance for corruption in any of its manifestations;

representative of the Center - a person authorized in accordance with the established procedure to act on behalf of or in the interests of the Center in relations with third parties;

official:

 a person authorized to perform the functions of the state or local self-government, in accordance with clause 1 Article 3, first paragraph, of the Act;

a person who is equivalent to persons authorized to perform the functions of the state or local self-government, in accordance with clause 2 Article 3, first paragraph, of the Act;

 a member of the patronage service in accordance with articles 92 of the Law of Ukraine "On Civil Service";

a candidate for the post of President of Ukraine and a candidate for People's Deputies of Ukraine, registered in accordance with the procedure established by law;

a manager, other official of a business association in which the state or communal share exceeds 50 percent;

an official of a foreign state (a person who holds a position in a legislative, executive or judicial body of a foreign state, including jurors, another person who performs the functions of a state for a foreign state, in particular for a state body or state enterprise);

a foreign arbitrator, a person authorized to resolve civil, commercial or labor disputes in a foreign state in an alternative judicial manner;

an official of an international organization (an employee of an international organization or any other person authorized by such an organization to act on its behalf);

member of the International Parliamentary Assembly, of which Ukraine is a member;

judge and official of an international court;

sponsorship activity (sponsorship) - voluntary material, financial, organizational and other support by the Organization for any event or activity aimed at popularizing the name of the Organization, signs for the Organization's goods and services.

 Other terms in this Policy are used in the meanings given in Laws or other acts of legislation in the field of prevention and counteraction of corruption.

1.4. The purpose of this Policy is to ensure the functioning of an effective system of preventing and countering corruption, compliance of the Center's activities with the requirements of the Law and other legislative acts in the field of preventing and countering corruption.

1.5. This Policy and other internal documents of the Center in the field of prevention and counteraction of corruption are mandatory for the director, deputy directors, heads of structural divisions, employees of the Center (hereinafter – personnel), representatives of the Center, persons who perform certain work on the basis of civil law contracts concluded with the Center.

1.6. This Policy is applied in all areas of the Center's activities, including relations with business partners, officials, state authorities and local self-government bodies, other legal entities and individuals.

1.7. Provisions concerning the obligation to comply with and implement this Policy and other internal documents of the Centre in the field of preventing and combating corruption are included in the Centre's internal labour regulations, structural unit regulations and job descriptions, as well as in anti-corruption and other reservations in treaties, memoranda, agreements of intent, joint protocols of other documents of the Centre.

1.8. The text of this Policy is available in permanent open access for personnel, representatives of the Center, persons who perform certain work on the basis of civil law contracts concluded with the Center, and is also provided to the Center's business partners.  

2. Responsible leadership, business reputation, integrity and professional ethics

2.1. The Director, Deputy Directors, and heads of the structural units of the Center undertake to demonstrate leadership and responsibility by personal example of ethical behavior to form employees, representatives of the Center and persons who perform certain work on the basis of civil law contracts concluded with the Center zero tolerance for corruption, which is the basis of business culture, everyday business practice and business reputation of the Center.

2.2. Staff, representatives of the Centre, persons performing certain work on the basis of civil law contracts concluded with the Centre in the performance of their official (contractual) duties:

(1) The generally recognized ethical norms of conduct and the requirements of the Code of Ethics and Business Conduct of the Centre are scrupulously observed;

2) Tolerant and respectful of the political views, ideological and religious beliefs of others;

(3) act notwithstanding personal interests, personal treatment of any persons, their political, ideological, religious or other personal views or beliefs;

(4) Do not disclose or use confidential information made known to them in connection with the performance of their official (contractual) duties, except in cases established by law;

(5) competently, timely, effectively and responsibly perform official (contractual) duties, decisions and assignments of officials to whom they are subordinate, accountable or under their control, and do not allow abuse and inefficient use of the Center's funds and property.

(6) refrain from carrying out clearly criminal acts, decisions and orders and take measures to revoke such decisions and orders, immediately reporting in writing the fact of such a decision or the granting of a mandate depending on the subject of its adoption/granting – to the immediate head/director of the Center and/or the Commissioner.

2.3. An official, employee, representative of the Centre or a person performing certain work on the basis of a civil law contract concluded with the Centre may not be dismissed or forced to dismiss or terminate the contract, disciplined or subjected by management to other negative measures of influence or to the threat of such measures of influence in connection with the refusal to execute decisions or orders that are clearly criminal and also for refusing to participate in corrupt acts, even if such refusal may lead to the Center losing its potential benefit.

3. Rights, Duties, Anti-Corruption Bans  

3.1. Staff, representatives of the Center, persons who perform certain work on the basis of civil law contracts concluded with the Center have the right:

(1) To provide suggestions for improving this Policy;

(2) seek advice and clarification from the Commissioner on the implementation of this Policy, other internal documents of the Centre relating to the prevention of corruption, and anti-corruption legislation.

3.2. Staff, representatives of the Centre, persons performing certain work on the basis of civil law contracts concluded with the Centre shall be obliged to:

1) comply with the requirements Law, the provisions of this Policy and the internal documents of the Center adopted for its implementation and ensure their implementation;

(2) To perform their official (contractual) duties, taking into account the legitimate interests of the Centre;

(3) to inform without delay, in the procedure provided for in this Policy, the Commissioner, the Director of the Center about cases of direct detection of violation of the requirements of this Policy (or incitement to such actions) or commission of corruption or corruption-related offenses, other violations Law;

(4) inform in the manner specified by this Policy about the occurrence of a real, potential conflict of interest; take measures to prevent and settle a real or potential conflict of interest; do not take actions and do not make decisions in conditions of a real conflict of interest;

(5) To refrain from conduct that may be regarded as a willingness to commit a corrupt or corruption-related offence related to the activities of the Centre;

(6) inform the Commissioner about the implementation and acceptance of business hospitality, giving and receiving gifts;

(7) to take into account and take into account the recommendations of the Commissioner.

3.3. Personnel, representatives of the Center, persons who perform certain work on the basis of civil law contracts concluded with the Center are prohibited:

(1) Accept an offer, promise or receive an undue advantage, and also request that such benefit be granted to themselves or another natural or legal person for committing or not committing any act using the position they occupy in the Centre, or in connection with their activities for the benefit of the Centre, in the interests of the person offering, promising or providing such benefit, or in the interests of a third party;

(2) abuse your powers, i.e. intentionally, in order to obtain an illegal benefit for yourself or another natural or legal person, use your powers contrary to the interests of the Center;

3) offer, promise or provide (directly or through a third party) officials and/or their relatives, other natural persons with an unlawful benefit for their commission or non-commitment of any actions /inaction using the power, official position, authority granted to them to obtain or maintain any benefits for the Center;

(4) To take actions and make decisions in the face of a real conflict of interest;

(5) Use any property of the Centre or its funds in the personal interest;

(6) organize, mediate or personally make any cash or non-cash payments or settlements with the Center's business partners, other natural or legal entities, if such payments or settlements are not provided for by law or contracts concluded by the Center or other documents aimed at the implementation of the Center's legal relations;

(7) To influence directly or indirectly the decisions of the Centre's employees with a view to obtaining undue advantage for themselves or others;

(8) to commit any act that directly or indirectly incites other officials at all levels, employees, representatives of the Center, or persons performing certain work on the basis of civil law contracts concluded with the Center to violate the requirements Law, the provisions of this Policy;

(9) to give and receive gifts in violation of the requirements of the law and this Policy regarding the provision and acceptance of business hospitality and gifts;

(10) upon release or other termination of cooperation with the Centre, disclose or otherwise use in their interests information, including confidential information, which has come to their knowledge in connection with the exercise of their powers, of contractual obligations, except as established by law.

3.3.1. The Centre shall prohibit the payment of incentive payments to officials, in particular with a view to expediting any formal procedures relating to the acquisition of permits or to taking appropriate decisions in favour of the Centre or to obtaining other benefits for the Centre.

A payment for accelerated consideration paid to the account of a state authority or local self-government body, enterprise, institution, organization, official, state/local budget, the amount and payment of which is provided for by law, is not encouraging (for example, a payment for accelerated registration of patents).

An official, employee, representative of the Center or a person who performs certain work on the basis of a civil law contract concluded with the Center to which a request for an incentive payment is made is obliged to inform the person making such a request about the prohibition of its implementation, to refuse to make such payment, as well as to immediately inform his immediate supervisor of another person to whom he is accountable and/or under the control and the Commissioner about the received demand.

If an official, employee, representative of the Center or a person who performs certain work on the basis of a civil law contract concluded with the Center has any doubt about the payment's belonging to the incentive payment and the prohibition of its implementation, such a person should seek advice from the Commissioner.

3.3.2. The prohibitions shall apply without any restriction on the territory of any State, notwithstanding national traditions, local practices or the conditions of competition in force in that State.

4. The legal status, rights, duties of the Commissioner and guarantees of his independence

4.1. The legal status of the Commissioner, as well as his rights, duties and guarantees of independence, are determined By law, this Policy, its regulations, job description and other internal documents of the Center.

The Commissioner is appointed by the Director of the Centre to a separate post in accordance with the labour laws and the Centre's constituent instruments.

The Commissioner is subordinate, accountable and under the control of the Director of the Centre.

4.1.1. In order to implement this Policy, by decision of the Director of the Center, responsible persons may be appointed in the branches, perform duties and enjoy the rights provided for by the Commissioner within the scope of the activities of the branches in which they work.

The Commissioner, within the scope of his official duties, has the right to give oral and written instructions and demand their execution from the responsible persons and supervises their activities.

4.2. The Commissioner's exercise of his functions in the Center is independent. Interference in the activities of the Commissioner is not allowed.

4.2.1. Intervention should be understood as:

(1) refusal to provide the Commissioner with information, documents, access to information and documents, the right to receive which the Commissioner has the right;

2) any influence on the Commissioner's decision-making and actions, which is carried out outside the powers of the person exercising influence, provided for by law, or internal documents of the Center (for example, providing instructions on the content of conclusions to be carried out by the Commissioner based on the results of an inspection of business partners; regarding the circle of persons - subjects of declaration, notification of facts of untimely submission of declarations that cannot be sent to the National Agency for the Prevention of Corruption, etc.);

3) actions/inactions that cause restrictions or violations of the Commissioner's rights (for example, unjustified refusal to grant annual leave on schedule; unjustified refusal to send for training/reservice training provided for in the relevant plan-schedule; unjustified limitation of the amount or non-payment of incentive and compensation payments provided for by labor and collective agreements, etc.);

4) acts/inactions that prevent the Commissioner from performing his duties (for example, unjustified sending of the Commissioner on a business trip away from the workplace; unjustified deprivation of the Commissioner's access to the workplace, personal computer; unjustified seizure of documents stored by the Commissioner; failure to provide the Commissioner with the material resources necessary to perform the tasks assigned to him, failure to provide access to the Center's record keeping system, means of communication, etc.);

(5) entrusting the Commissioner with duties, giving instructions on matters not belonging to or beyond his powers, defined by By law but they limit the performance of his official duties.

4.2.2. The Commissioner may not be dismissed or forced to dismiss, disciplined or subjected to other negative measures of influence (transfer, attestation, change of working conditions, refusal to be appointed to a higher position, reduction of wages, refusal to extend the employment contract, etc.) or to the threat of such measures of influence in connection with the implementation of anti-corruption measures, detection and reporting of possible facts of corruption or corruption-related offenses, other violations Law.

Negative measures of influence also include formally legitimate decisions and actions that are selective in nature, in particular, they do not apply to other employees, managers in similar situations and/or have not been applied to the Commissioner in similar situations (in similar circumstances) before.

5. Informing, training activities, providing clarification and advice to the Commissioners

5.1. In order to form an adequate level of anti-corruption culture, the Commissioner ensures that the regulations are kept informed Law, of this Policy and the internal documents of the Center of newly appointed employees adopted for its implementation.

5.2. The Commissioner organizes sufficient information about the provisions of this Policy and the internal documents of the Center adopted for its implementation by representatives of the Center and persons who perform certain work on the basis of civil law contracts concluded with the Center, business partners of the Center in the part that concerns them.

5.3. Anti-corruption training activities are implemented by the Commissioner both remotely and in person.

5.4. The subject matter and form of training activities shall be determined in particular taking into account:

1) changes in legislation;

2) Staff proposals;

3) the results of the periodic assessment of corruption risks in the Center's activities;

(4) the results of inspections of compliance with anti-corruption legislation.

5.5. If there are questions regarding the clarification of certain provisions of this Policy, any of the staff, representatives of the Center, persons performing certain work for the Center may apply to the Commissioner for oral or written clarification or consultation.

5.6. The Commissioner shall provide clarification or advice within a reasonable time, but not more than 10 days from the date of receipt of the request.

5.7. The Commissioner may summarise the most common questions addressed to him, the answers to them and place them in the form of generalised explanations of monuments, guidelines, etc. on publicly available resources and/or by means of e-mail.

6. Measures to prevent corruption in the activities of the Center

6.1. Management of corruption risks

6.1.1. In order to effectively prevent corruption in its activities, the Center applies a risk-oriented approach and creates a risk management system, which involves regular assessment of corruption risks that may be affected by the Center's activities, taking measures necessary and sufficient to eliminate or minimize them, their further monitoring and control, as well as updating existing anti-corruption measures in accordance with changes in the internal and external environment of the Center's activities.

6.1.2. The Center carries out periodic assessment of corruption risks in its activities, the purpose of which is:

(1) identification of internal and external corruption risks in the Center's business processes;

(2) assessing the adequacy, appropriateness and effectiveness of existing measures to adequately prevent, eliminate or minimize identified corruption risks;

3) analysis and assessment (determination of levels) of identified corruption risks;

(4) prioritization of high-risk business processes, taking into account the nature and degree of vulnerability of business processes to corruption risks, the levels of assessed corruption risks;

(5) development of measures with a view to effectively eliminating or minimizing corruption risks in the Centre's activities.

6.1.3. The organization of periodic assessment of corruption risks in the Center's activities is carried out by the Commissioner.

6.1.4. The Center can carry out internal and/or external assessment of corruption risks.

Internal assessment of corruption risks is carried out by a working group formed from representatives of the Center's structural divisions.

External assessment of corruption risks can be carried out by auditing, legal, consulting companies or independent experts involved by the Center.

6.1.5. The Center assesses corruption risks in its activities at least once every 2 years.

6.1.6. The Center evaluates corruption risks according to the procedure defined by the Center's internal documents or may make a decision on the evaluation of corruption risks according to the procedure defined by law.

6.1.7. The Commissioner monitors the implementation of measures to eliminate or minimize identified corruption risks, prepares reports on the state of implementation of measures in the manner and terms determined by the Center's internal documents.

6.2. Prevention and settlement of conflicts of interest

6.2.1. The Centre shall seek to ensure that conflicts of interest do not adversely affect the interests of the Centre as well as those of its business partners by preventing, detecting and settling conflicts of interest.

6.2.2. The Center prevents and regulates situations of conflict of interest based on the following principles:

(1) The obligation to inform about situations showing signs of conflict of interest;

2) preventing the occurrence of a real conflict of interest;

(3) an individual approach in the consideration and assessment of each individual case, which has signs of a conflict of interest.

6.2.3. Officials, employees of the Center, are obliged to notify their immediate supervisor in writing about this to another person to whom they are under the control or accountability and the Commissioner, not to take actions and not to make decisions in conditions of a real conflict of interests and to take measures to resolve a real or potential conflict of interests.

In the event of a real or potential conflict of interest in the director of the Center, he shall notify the Commissioner and the person/body whose authority (who) is to be dismissed/initiated from the position of director of the Center in writing.

In the event of a real or potential conflict of interest among representatives of the Center or persons performing certain work on the basis of a civil law contract concluded with the Center, they notify the Commissioner in writing, who submits proposals on the method of resolving the conflict of interest to the director of the Center within two working days after receiving the notification.

In the event of a real or potential conflict of interest in the Commissioner, he shall notify the Director of the Centre in writing.

Notification of a conflict of interest must be carried out no later than the next working day from the day when the relevant person found out or should have found out about the existence of a real or potential conflict of interest.

6.2.4. Within two working days after receiving a notification about the presence of a person subordinate to him of a real or potential conflict of interest, the direct manager of the person makes a decision on the method of resolving the conflict of interest, taking into account the recommendations of the Commissioner, which informs the employee.  

6.2.5. The immediate supervisor who becomes aware of a conflict of interest in an employee subordinate to him (including in the case of independent detection of a conflict of interest existing in his subordinate, without him making the appropriate notification) is obliged to inform the Commissioner and take the measures provided for in this Policy to prevent and settle the conflict of interests.

6.2.6. Conflict of interest resolution is carried out using one of the following measures (individually or in combination):

(1) removing a person from performing a task, taking actions, making a decision or participating in its adoption in conditions of real or potential conflict of interest;

(2) application of external control over the person's performance of the relevant task, his performance of certain actions or decision-making;

3) restricting a person's access to certain information;

4) review of the scope of the person's job (functional) responsibilities;

5) Transfer of a person to another position;

6) dismissal (termination of civil legal relations) with a person.

6.2.7. Recommendations on conflict of interest resolution measures and its features for various categories are provided by the Commissioner, taking into account the following requirements:

(1) transfer of a person to another position is applied only with his consent in the event that a real or potential conflict of interest in his activities is of a permanent nature and cannot be settled in another way and in the presence of a vacant position that corresponds to his personal and professional qualities in terms of its characteristics;

(2) the dismissal of a person from his position due to the presence of a conflict of interest is carried out if the real or potential conflict of interest in his activities is of a permanent nature and cannot be settled in another way, including due to the lack of his consent to transfer or to deprivation of private interest;

(3) in the event of a representative of the Center or a person who performs certain work on the basis of a civil law contract concluded with the Center for Conflict of Interests, which has a permanent nature, the Center terminates legal relations with them with the entry of its data into the list of persons whose services are not subject to use and/or for whose benefit payments cannot be made in the future.  

6.2.8. The decision to resolve the conflict of interests in the activities of the director of the Center is made by a person or body (including a collegial one) whose powers include dismissal/initiation of dismissal from the position of director of the Center, in the manner and terms established by law.  

6.2.9. Officials, employees, representatives of the Center, as well as persons who perform certain work on the basis of civil law contracts concluded with the Center can independently take measures to resolve conflicts of interest by depriving the relevant private interest with the provision of supporting documents to the immediate manager and/or Commissioner.

6.2.10. The Director of the Center can independently take measures to resolve the conflict of interests by depriving the relevant private interest with the provision of supporting documents to the Commissioner, as well as to the person or body (including the collegial one) whose authority (whom) the dismissal/initiation of dismissal from the position of the director of the Center belongs to.

6.2.11. In the event of a real or potential conflict of interest in a person who is a member of a collegial body (commission, working group of the Center, etc.), during the resolution of the issue by this body, such a person notifies the relevant collegial body and the Commissioner in writing.

6.2.12. The specified person is prohibited:

(1) To participate in the preparation of documents for decision by the collegiate body on the relevant issue;

2) participate in the consideration (discussion) of the relevant issue;

(3) vote on the relevant issue.

6.2.13. In the event that the non-participation of a member of the collegial body of the Center leads to the loss of the authority of this body, the participation of such a person in decision-making should be carried out under external control. The decision to exercise external control is made by the relevant collegial body.

6.2.14. External control is carried out by the participation of the Commissioner in the work of the collegial body in the status of an observer without the right to vote.

6.2.15. Typical situations of conflict of interest can be:

(1) participation in the adoption or adoption of a decision on the conclusion of an employment contract, promotion at work, determination of terms of payment and application of measures of financial encouragement, imposition of fines against a close person;

(2) preparation, participation in the conclusion of contracts or other documents with close persons on behalf of the Center;

(3) the participation of a person subject to the requirements of this Policy in the adoption or adoption of a decision that may affect the receipt of benefits by another business entity over whose business decisions such person or a close person exercises actual control, in which such person, his close person are founders (participants), employees, receive or have received remuneration or gifts, have undergone or are undergoing training;

(4) registration by a person subject to the requirements of this Policy, a natural person - an entrepreneur or the formation by such a person of a legal entity that provides services /performs work identical to that provided/performed by the Center;

(5) performing the functions of a senior-level manager in another legal entity whose interests may come into conflict with those of the Center;

(6) acceptance or participation in the adoption by a person subject to the requirements of this Policy of decisions regarding himself, in particular regarding remuneration, provision of any benefit of a material or non-material nature, conducting disciplinary proceedings.

6.3. Interaction with business partners

6.3.1. The Center seeks to cooperate with business partners who carry out their activities legally and ethically, interaction with which does not pose corruption or other risks for the Center.

6.3.2. The Center informs business partners before establishing business relations with them about the principles and requirements of the Center in the field of prevention and counteraction of corruption, which are provided for in this Policy and the internal documents of the Center adopted for its implementation in the part that concerns them.

6.3.3. The Center checks potential business partners (before the date of conclusion of contracts with them, or signing of other documents aimed at the implementation of legal relations with the Center) and existing business partners (after establishing legal relations with them).

6.3.4. The procedure for checking the Center's business partners is determined in its internal documents, which are developed by the Commissioner and approved by the Center's director.

6.3.5. Anti-corruption clauses may be included in contracts or other documents aimed at implementing the Center's legal relations with business partners, which the Center concludes (signs) with them. The purpose of the anti-corruption clause is for the Center to provide guarantees of its compliance with anti-corruption legislation, the requirements of this Policy and the Center's internal documents adopted for its implementation, and to obtain similar guarantees from a business partner.

Editions of anti-corruption reservations are developed by the Commissioner.

6.4. Business Hospitality Policy and Gifts

6.4.1. Taking into account the requirements of the law, the center determines the general policy of providing and accepting business hospitality and gifts.

6.4.2. Staff, representatives of the Centre, persons performing certain work on the basis of civil law contracts concluded with the Centre shall be obliged to refrain from offering business hospitality, gifts to officials, their close associates, actual or potential business partners, their employees or representatives, if such business hospitality, gifts may be regarded as inducement or readiness to commit a corruption offence related to the Centre's activities.

6.4.3. Giving and receiving gifts, as well as providing and accepting business hospitality within the framework of establishing or maintaining business relations or to achieve another goal of the Center's activity, are allowed if they meet a set of the following criteria:

(1) do not aim to influence the objectivity of any decision regarding the conclusion of contracts or the signing of other documents aimed at the implementation of the Center's legal relations with business partners, providing or receiving services, information, any other advantages for the Center;

2) is not a hidden undue benefit (for example, to receive or continue to receive commercial orders or an improper advantage);

3) correspond to generally accepted ideas about hospitality (for example, a gift is a souvenir product);

(4) Not prohibited by the law of the State in which they are granted and/or accepted;

(5) the value does not exceed the limits established by law;

6) are not prohibited in accordance with the internal documents of the recipient's organization and do not exceed the value established by such documents;

(7) disclosure of the gift, business hospitality will not create a risk to the business reputation of the Center or the person who received the gift, business hospitality;

8) gifts, business hospitality are reasonable, non-excessive and appropriate in the context of establishing/maintaining business relations.

6.4.4. Donations and receiving gifts in the form of cash (cash or non-cash), cash equivalent (gift cards or gift vouchers) are not allowed.

6.5. Charitable, sponsorship activities, as well as support of political parties

6.5.1. The center can carry out charitable and sponsorship activities in the absence of prohibitions established by law.

6.5.2. Charitable and sponsored activities are not allowed by the Center if:

(1) its implementation is a condition for the conclusion of any contract or other documents aimed at the implementation of the Center's legal relations, the adoption of a decision by a state authority or a local self-government body, or it is carried out for the purpose of obtaining illegal advantages in business activities;

(2) the business partner/official insists on carrying out one or another type of charitable and/or sponsorship activity exclusively through a specific organization;

(3) it is carried out for the purpose of influencing an official or in exchange for any undue benefit to the Center from a business partner.

6.5.3. The center keeps records and financial statements of contributions made by it to charitable and sponsorship activities.  

6.5.4. The Center does not support political parties, if this is prohibited by law.

6.6. Integrity test of candidates for positions and employees

6.6.1. In order to ensure the integrity of candidates for positions and employees of the Center, as well as to prevent them from having a conflict of interest, the Center ensures the implementation of a set of organizational and practical measures for checking and analyzing information provided by candidates/employees in declarations of integrity and notifications of private interests.

6.6.2. The procedure for checking the integrity of candidates for positions and employees of the Center is developed by the Commissioner and approved by the Director of the Center.

6.7. Reporting possible facts of corruption or corruption-related offences and other violations  Law

 6.7.1. The Centre builds respect for whistleblowers as part of its business culture and provides them with the conditions to carry out notification of possible facts of corruption or corruption-related offences, other violations Law (hereinafter – Notification), in particular by:

(1) implementation of Messages through the Unified Whistleblower Message Portal and other channels, including anonymously;

 2) definition according to Law internal procedures and mechanisms for the adoption and consideration of, verification of and appropriate response to Communications;

(3) provision of methodological assistance and advice on the implementation of the Notice to potential whistleblowers;

(4) respect for whistleblower rights and safeguards.

6.7.2. Information on the channels and modalities for the implementation of the Communications is necessarily brought to the attention of staff, representatives of the Centre, persons performing certain work on the basis of civil law contracts concluded with the Centre and the Centre's business partners.

7. Monitoring the implementation of the requirements of the Policy and disciplinary responsibility for their violation  

7.1. The Commissioner shall carry out constant monitoring of compliance with the requirements of this Policy by:

(1) review and response to Notices;

(2) carrying out visa of draft contracts or other documents aimed at the implementation of the Center's legal relations with business partners, as well as draft orders of the Center for the presence of corruption and other risks;

(3) application of other forms of control that can be determined by the director of the Center based on the Commissioner's proposals (procedure for carrying out scheduled and unscheduled inspections of personnel activities; procedure for conducting inspections of Center documents, etc.).

7.2. If, in the course of monitoring compliance with the requirements of this Policy, the Commissioner finds signs of committing a corruption or corruption-related offence, he shall initiate and participate in disciplinary proceedings before the Director of the Centre.

7.3. For violation of the provisions of this Policy, disciplinary measures are applied to the Center's employees in accordance with the legislation, the rules of the Center's internal labor regulations, job instructions, and the provisions of employment contracts.

7.4. The Centre's Personnel and Administrative Support Division sends to the National Agency for the Prevention of Corruption a certified paper copy of the decision (order) of the Director of the Centre imposing a disciplinary penalty and an information card to the administrative document imposing (cancellation of the administrative document imposing) a disciplinary penalty on a person for the commission of corruption or corruption-related offences in order to enter information on the imposition of a disciplinary penalty for the commission of corruption or corruption-related offences to the Unified State Register of Persons Who Have Committed Corruption or Corruption-Related Offences.

Commissioner for Anti-Corruption Robert SIEVERS