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Humanitarian demining without manipulation: what's behind the compensation program numbers

17.07.2025

Currently, there is a lot of manipulation in the public space by people far from the topic of humanitarian demining, who are trying to gain public attention through high-profile statements.

In particular, the claim is spreading that the state program for compensation for demining agricultural land (compensation program) is allegedly ineffective, because out of the planned 3 billion hryvnias in 2025, only about 300 million hryvnias were spent.

But to assess the situation more professionally, we suggest turning to real numbers and trends, rather than manipulative headlines.

Regarding areas

Since the beginning of the full-scale invasion, 36,942 km² of territories have been returned to productive use. Of these, 94 km² (or 9.4 thousand hectares) have been cleared, and the rest of the area has been released based on the results of non-technical surveys.

Of this cleared area, about 2.8 thousand hectares were returned to cultivation by private mine action operators (PMAs) under the compensation program - that is, almost 30% . This is an indicator that could not be achieved in previous years.

In addition, as of today, more than 11,000 hectares are actively being demined under the same program. If these areas are cleared by the end of the summer, the volume of humanitarian demining could almost double.

It should be emphasized separately: when comparing figures , one should not confuse humanitarian demining with rapid response. Rapid response does cover larger areas, but it does not provide for the depth and thoroughness of clearance, the standards of verification that are mandatory for humanitarian demining. These are two different processes in essence and complexity.

"Humanitarian demining is much more complicated than rapid response: it involves a number of certified procedures and uses standardized methods. Only after the completion of such work and a professional inspection is the land officially considered cleared and a certificate is issued for it. Rapid response is a quick surface clearance, which is carried out, for example, by employees of the State Emergency Service, but it does not guarantee full clearance of the land. Humanitarian demining is carried out exclusively by certified state and private PMD operators according to clearly defined procedures," emphasized Volodymyr Bayda, Director of the Humanitarian Demining Center.

Regarding funds

Let's explain where the sum of 3 billion hryvnias came from, and how the cost of humanitarian demining is formed.

Before the launch of the compensation program, PMD operators and international organizations operated at an average market price of $3 per square meter, or approximately $30,000 per hectare of work . At the NBU exchange rate (1 dollar = 41.8 hryvnias), this is about 1,254,000 hryvnias per hectare.

So, if we divide the total budget of the compensation program (3 billion UAH) by the average cost of clearing one hectare (1,254,000 UAH), we get approximately 2,400 hectares - this is exactly the amount the budget would be enough for at the average international cost of demining.

Instead, over 3,000 hectares have already been cleared under the compensation program to date. That is, the area actually cleared is larger than what the same budget would have allowed according to the partners' calculations. This was made possible thanks to cost optimization and competition between PMD operators. 

The cost of demining 1 hectare of land under the compensation program is 20 times lower than the average international price.

This demonstrates the effectiveness of the program not only in terms of achieved results, but also in terms of financial management. Costs have been reduced, and the effect has exceeded expectations.

Regarding the validity of the claims

So, before making loud statements about the program's ineffectiveness, it's worth analyzing the real numbers. And these numbers prove that the compensation program works, works effectively, and has significant potential for scaling.

Another topic that is often raised in the public space is appeals from farmers who insist that their fields are mined. But during the consideration of applications, there were cases when 80-90% of the land submitted by the farmer was already being cultivated - without official clearance. That is, program participants submitted applications for compensation for the demining of already sown lands.

It is important to understand this: the task of the compensation program is not to “give money to everyone,” but to provide compensation for safe, high-quality, and legally confirmed land demining.

Regarding transparency

The work of the Humanitarian Demining Center is audited by the Accounting Chamber, the State Audit Service of Ukraine, and requests are systematically received from the Security Service of Ukraine. Every step – from confirmation of the application to completion of the work – is documented and verified.

Therefore, we call for refraining from populism. Instead of manipulation, let's work with proven figures, facts, and results.

We support broader coverage of the topic of humanitarian demining in the media, social networks, and messengers. However, we urge you to disseminate professional information, citing official sources, and not speculation or manipulation.

       APPROVED

      Order of the Center for Humanitarian

demining

                   "30" December 2024 No. 59

 Anti-corruption policy 

Humanitarian Demining Center  

1. General provisions

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

1.2. By this Policy, the Center declares that in its activities, including in legal relations with business partners, officials, state authorities, and local governments, 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 combat corruption and any related actions (corrupt practices).

1.3. In this Policy, the following terms are used with 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 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 incurred by the Center or in relation to the Center for the purpose of establishing or establishing business relations or for another purpose related to the activities of the Center;

business relations - relations between the Center and a business partner related to the business, professional or economic activities of the Center, which arose on the basis of an agreement or by concluding memoranda, agreements of intent, joint protocols, etc. (except for state bodies of Ukraine, international organizations of which Ukraine is a member, international technical assistance projects that have undergone appropriate state registration) for the achievement of common interests and provide for the duration of their existence after their establishment;

business partner – any legal entity, individual or individual entrepreneur with whom the Center intends to establish contractual or other business relations (potential business partner) or already has such contractual or other business relations (existing business partner);

Incentive payments - unofficial and illegal payments to officials for the purpose of facilitating/accelerating/simplifying or, in certain cases, the proper execution of 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, or other violation of the Law , which will negatively affect the activities and/or business reputation of the Center;

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

zero tolerance for corruption - absolute intolerance to 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 person:

 a person authorized to perform state or local government functions, in accordance with paragraph 1 of part one of Article 3 of the Law;

a person who is equated with persons authorized to perform state or local government functions, in accordance with clause 2 of part one of Article 3 of the Law;

 an employee of the patronage service in accordance with Article 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;

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

official of a foreign state (a person holding a position in a legislative, executive or judicial body of a foreign state, including jurors, another person performing state functions for a foreign state, in particular for a state body or state enterprise);

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

an official of an international organization (an employee of an international organization or any other person authorized by such 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 (sponsorship) - voluntary material, financial, organizational and other support by the Organization of any event or activity with the aim of popularizing the name of the Organization, trademarks for the Organization's goods and services.

Other terms used in this Policy have the meanings given in the Law or other legislative acts in the field of preventing and combating corruption.

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

1.5. This Policy and other internal documents of the Center in the field of preventing and combating corruption are mandatory for implementation by the director, deputy directors, heads of structural units, employees of the Center (hereinafter referred to as the personnel), representatives of the Center, and persons performing certain work on the basis of civil law contracts concluded with the Center.

1.6. This Policy applies to all areas of the Center's activities, including relations with business partners, officials, state authorities and local governments, and other legal entities and individuals.

1.7. Provisions on the mandatory observance and implementation of this Policy and other internal documents of the Center in the field of preventing and combating corruption are included in the internal labor regulations of the Center, provisions on structural units and job descriptions, as well as in anti-corruption and other provisions in contracts, memoranda, agreements of intent, joint protocols and other documents of the Center.

1.8. The text of this Policy is available in constant open access for staff, representatives of the Center, persons performing 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 structural divisions of the Center undertake to demonstrate leadership and responsibility by personal example of ethical behavior to form among employees, representatives of the Center, and persons performing certain work on the basis of civil law contracts concluded with the Center zero tolerance for corruption, which is the basis of the business culture, everyday business practices, and business reputation of the Center.

2.2. Personnel, representatives of the Center, persons who perform certain work on the basis of civil law contracts concluded with the Center during the performance of their official (contractual) duties:

1) strictly adhere to generally recognized ethical standards of conduct and the requirements of the Center's Code of Ethics and Business Conduct;

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

3) act regardless of personal interests, personal attitude towards any persons, or their political, ideological, religious or other personal views or beliefs;

4) do not disclose or use confidential information that has become 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 instructions of officials to whom they are subordinate, accountable or controlled, and prevent abuse and inefficient use of the Center's funds and property.

6) refrain from carrying out clearly criminal actions, decisions and instructions and take measures to cancel such decisions and instructions, immediately reporting in writing the fact of such a decision or provision of an instruction, depending on the subject of its adoption/provision - the immediate manager/director of the Center and/or the Commissioner.

2.3. An official, employee, representative of the Center or a person performing certain work on the basis of a civil law contract concluded with the Center may not be dismissed or forced to resign or terminate the contract, held disciplinary liable or subjected to other negative measures of influence or the threat of such measures of influence by management in connection with refusal to execute decisions or instructions that are clearly criminal, as well as for refusal to participate in corrupt acts, even if such refusal may result in the Center losing potential benefits.

3. Rights, obligations, anti-corruption prohibitions 

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

1) provide suggestions for improving this Policy;

2) contact the Commissioner for consultations and clarifications regarding the implementation of this Policy, other internal documents of the Center regarding corruption prevention, and anti-corruption legislation.

3.2. Personnel, representatives of the Center, persons performing certain work on the basis of civil law contracts concluded with the Center are obliged to:

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

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

3) immediately inform the Commissioner, the Director of the Center, in the manner provided for by this Policy, about cases of direct detection of violations of the requirements of this Policy (or incitement to such actions) or the commission of corruption or corruption-related offenses, other violations of the Law ;

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

5) refrain from behavior that may be perceived as a willingness to commit a corruption or corruption-related offense related to the activities of the Center;

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

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

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

1) accept an offer, promise or receive an improper benefit, as well as request such benefit for themselves or another individual or legal entity for committing or failing to commit any actions using the position they hold in the Center, or in connection with their activities for the benefit of the Center, in the interests of the person who offers, promises or provides such benefit, or in the interests of a third party;

2) abuse their powers, that is, intentionally, in order to obtain an improper benefit for themselves or another individual or legal entity, use their powers contrary to the interests of the Center;

3) offer, promise or provide (directly or through a third party) to officials and/or their close associates, other individuals, an improper benefit for their taking or failing to take any actions/inaction using the power, official position, or authority granted to them to obtain or retain any benefits for the Center;

4) take actions and make decisions in conditions of real conflict of interest;

5) use any property of the Center or its funds for personal interests;

6) organize, be an intermediary or personally make any cash or non-cash payments or settlements with the Center's business partners, other individuals or legal entities, if such payments or settlements are not provided for by law or agreements concluded by the Center or other documents aimed at implementing the Center's legal relations;

7) directly or indirectly influence the decisions of the Center's employees in order to obtain improper benefit for themselves or other persons;

8) take any actions that directly or indirectly incite other officials of 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 of the Law and the provisions of this Policy;

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

10) after dismissal or other termination of cooperation with the Center, disclose or otherwise use in their own interests information, including confidential information, which became known to them in connection with the performance of their powers and contractual obligations, except for cases established by law.

3.3.1. The Center prohibits the payment of incentive payments to officials, in particular for the purpose of accelerating any formal procedures related to obtaining permits or making relevant decisions in favor of the Center or obtaining other benefits for the Center.

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

An official, employee, representative of the Center or a person performing certain work on the basis of a civil law contract concluded with the Center to which a demand for an incentive payment is addressed is obliged to notify the person making such a demand of the prohibition of its implementation, refuse to make such a payment, and also immediately inform his immediate supervisor, another person to whom he is accountable and/or supervised, and the Commissioner about the received demand.

If an official, employee, representative of the Center or a person performing certain work on the basis of a civil law contract concluded with the Center has any doubt as to whether a payment is an incentive payment and whether its implementation is prohibited, such person must seek advice from the Commissioner.

3.3.2. The prohibitions shall apply without any restrictions in the territory of any state, regardless of national traditions, local practices or conditions of competition in force in that state.

4. Legal status, rights, obligations of the Commissioner and guarantees of his independence

4.1. The legal status of the Commissioner, as well as his rights, obligations and guarantees of independence are determined by the Law , this Policy, the regulations on him, the job description and other internal documents of the Center.

The Commissioner is appointed by the Director of the Center to a separate position in accordance with labor legislation and the founding documents of the Center.

The authorized person is subordinate, accountable and controlled by the Director of the Center.

4.1.1. To implement this Policy, by decision of the Director of the Center, responsible persons may be appointed in the branches, who perform the duties and exercise 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/her official duties, has the right to give oral and written instructions and demand their execution from responsible persons, and exercises control over their activities.

4.2. The Commissioner shall exercise his/her functions in the Center independently. Interference in the Commissioner's activities shall not be permitted.

4.2.1. Intervention should be understood as:

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

2) any influence on the Commissioner's decision-making and actions that is carried out outside the powers of the person exerting the influence, as provided for by law or internal documents of the Center (for example, providing instructions on the content of the conclusions to be made by the Commissioner based on the results of the inspection of business partners; on the range 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/inaction that cause restrictions or violations of the Commissioner's rights (for example, unjustified refusal to provide annual leave according to the schedule; unjustified refusal to send for training/improvement of qualifications provided for by the relevant schedule; unjustified restriction of the amount or non-payment of incentive and compensation payments provided for by labor and collective agreements, etc.);

4) actions/inaction that impede the performance of official duties by the Commissioner (for example, unjustified sending the Commissioner on a business trip away from the workplace; unjustified deprivation of the Commissioner of 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 office management system, means of communication, etc.);

5) assigning duties to the Commissioner, giving instructions on issues that do not belong to or go beyond his powers defined by the Law and limit his performance of official duties.

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

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

5. Information, training activities, provision of explanations and consultations to the Commissioners

5.1. In order to form an appropriate level of anti-corruption culture, the Commissioner ensures mandatory information about the provisions of the Law , this Policy and the internal documents of the Center adopted for its implementation to newly appointed employees.

5.2. The Commissioner shall organize sufficient information about the provisions of this Policy and the internal documents of the Center adopted for its implementation to the representatives of the Center and persons who perform certain work on the basis of civil law contracts concluded with the Center, and the 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 topic and form of training activities are determined, in particular, taking into account:

1) changes in legislation;

2) staff suggestions;

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

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

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

5.6. The Commissioner shall provide clarification or consultation within a reasonable time, but no more than 10 days from the date of receipt of the application.

5.7. The Commissioner may summarize the most common questions addressed to him, the answers to them, and post them in the form of generalized explanations of monuments, manuals, etc. on publicly available resources and/or by e-mail.

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

6.1. Corruption risk management

6.1.1. To effectively prevent corruption in its activities, the Center applies a risk-based approach and creates a risk management system that provides for regular assessment of corruption risks that may affect 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 conducts periodic assessments of corruption risks in its activities, the purpose of which is to:

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

2) assessment of 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, and the levels of assessed corruption risks;

5) development of measures to effectively eliminate or minimize corruption risks in the activities of the Center.

6.1.3. The Commissioner shall organize the periodic assessment of corruption risks in the activities of the Center.

6.1.4. The Center may conduct internal and/or external assessments 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 engaged 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 carries out an assessment of corruption risks according to the procedure specified in the internal documents of the Center or may decide to carry out an assessment of corruption risks according to the procedure specified by law.

6.1.7. The Commissioner monitors the implementation of measures to eliminate or minimize identified corruption risks, prepares reports on the status of implementation of measures in the manner and within the time limits specified by the Center's internal documents.

6.2. Prevention and resolution of conflicts of interest

6.2.1. The Center strives to ensure that conflicts of interest do not adversely affect the interests of the Center, as well as the interests of its business partners, by preventing, identifying and resolving conflicts of interest.

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

1) the obligation to inform about situations that have signs of a conflict of interest;

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

3) an individual approach when considering and evaluating each individual case that has signs of a conflict of interest.

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

In the event of a real or potential conflict of interest for the Director of the Center, he shall notify the Commissioner and the person/body authorized to dismiss/initiate dismissal 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 shall notify the Commissioner in writing, who shall submit proposals on how to resolve the conflict of interest to the Director of the Center within two working days of receiving the notification.

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

A notification of a conflict of interest must be made no later than the next business day from the day on which the relevant person became aware or should have become aware of the existence of a real or potential conflict of interest.

6.2.4. The person's immediate supervisor, within two working days of receiving notification of a real or potential conflict of interest in a subordinate, shall, taking into account the recommendations of the Commissioner, make a decision on the method of resolving the conflict of interest, of which the employee shall be notified. 

6.2.5. A direct supervisor who becomes aware of a conflict of interest in a subordinate employee (including in the event of independent identification of a conflict of interest in a subordinate without the subordinate making a corresponding notification) is obliged to inform the Commissioner and take the measures provided for in this Policy to prevent and resolve the conflict of interest.

6.2.6. Conflict of interest shall be resolved by one of the following measures (separately or in combination):

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

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

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

4) review of the scope of a 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 measures to resolve conflicts of interest and their specifics for different categories are provided by the Commissioners taking into account the following requirements:

1) the transfer of a person to another position is applied only with his/her consent if the real or potential conflict of interest in his/her activities is of a permanent nature and cannot be resolved in another way and if there is a vacant position that, by its characteristics, corresponds to his/her personal and professional qualities;

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

3) in the event of a conflict of interest that is permanent in nature for a representative of the Center or a person performing certain work on the basis of a civil law contract concluded with the Center, the Center terminates legal relations with them and enters their data into the list of persons whose services cannot be used and/or in whose favor payments cannot be made in the future. 

6.2.8. The decision to resolve a conflict of interest 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 accordance with the procedure and terms established by law. 

6.2.9. Officials, employees, representatives of the Center, as well as persons performing certain work on the basis of civil law contracts concluded with the Center may independently take measures to resolve a conflict of interest by disclaiming the relevant private interest and providing supporting documents to their immediate supervisor and/or the Commissioner.

6.2.10. The Director of the Center may independently take measures to resolve the conflict of interest by disclaiming the relevant private interest with the provision of supporting documents to the Commissioner, as well as to the person or body (including a collegial one) whose powers include dismissal / initiation of dismissal from the position of Director of the Center.

6.2.11. In the event of a real or potential conflict of interest for 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 person shall notify the relevant collegial body and the Commissioner in writing.

6.2.12. The specified person is prohibited from:

1) participate in the preparation of documents for the decision-making of the collegial body on the relevant issue;

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

3) vote on the relevant issue.

6.2.13. If the non-participation of a member of the Center's collegial body results in the loss of the authority of this body, the participation of such a person in decision-making must 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 through 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 may be:

1) participation in making or taking a decision on concluding an employment contract, job promotion, determining the terms of remuneration and applying financial incentives, imposing penalties on a close person;

2) preparation, participation in the conclusion of agreements or other documents with related parties on behalf of the Center;

3) participation of a person subject to the requirements of this Policy in making or adopting a decision that may affect the receipt of benefits by another business entity, over whose business decisions such person or his/her close person exercises actual control, in which such person or his/her 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 as an individual entrepreneur or the formation by such a person of a legal entity that provides services/performs work identical to those provided/performed by the Center;

5) performing the functions of a senior manager in another legal entity whose interests may conflict with the interests of the Center;

6) making or participating in making decisions regarding oneself by a person subject to the requirements of this Policy, in particular regarding remuneration, granting any material or non-material benefit, and conducting disciplinary proceedings.

6.3. Interaction with business partners

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

6.3.2. The Center informs business partners, prior to establishing business relations with them, about the principles and requirements of the Center in the field of preventing and combating corruption, which are provided for by this Policy and the internal documents of the Center adopted for its implementation, in the part that applies to them.

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

6.3.4. The procedure for conducting an audit of the Center's business partners is determined in its internal documents, which are developed by the Commissioner and approved by the Director of the Center.

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 to provide the Center with guarantees of 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 the business partner.

The wording of anti-corruption provisions is developed by the Commissioner.

6.4. Business Hospitality and Gifts Policy

6.4.1. The Center, taking into account the requirements of the law, determines the general policy for providing and accepting business hospitality and gifts.

6.4.2. Personnel, representatives of the Center, persons performing certain work on the basis of civil law contracts concluded with the Center are obliged to refrain from offering business hospitality, gifts to officials, their relatives, actual or potential business partners, their employees or representatives, if such business hospitality, gifts can be regarded as an incitement or readiness to commit a corruption offense related to the activities of the Center.

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

1) are not intended to influence the objectivity of any decision regarding the conclusion of contracts or the signing of other documents aimed at implementing the Center's legal relations with business partners, providing or receiving services, information, or any other benefits for the Center;

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

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

4) are not prohibited by the legislation of the state in which they are provided and/or accepted;

5) the cost does not exceed the limits established by law;

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

7) disclosure of a gift or business hospitality will not create a risk to the business reputation of the Center or the recipient of the gift or business hospitality;

8) gifts and business hospitality are reasonable, not excessive and appropriate in the context of establishing/maintaining business relationships.

6.4.4. Giving and receiving gifts in the form of money (cash or non-cash) or cash equivalents (gift cards or gift vouchers) is not allowed.

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

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

6.5.2. The Center is not allowed to carry out charitable or sponsorship activities if:

1) its implementation is a condition for concluding any agreement or other documents aimed at implementing the legal relations of the Center, adopting a decision by a state authority or local government body, or it is carried out with the aim of obtaining illegal advantages in business activities;

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

3) it is carried out with the aim of influencing an official or in exchange for any improper benefit for the Center from a business partner.

6.5.3. The Center keeps records and financial statements of contributions made to charitable and sponsorship activities. 

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

6.6. Integrity check 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 to verify and analyze the information provided by candidates/employees in declarations of integrity and notifications of private interests.

6.6.2. The procedure for verifying 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 offenses and other violations Law

 6.7.1. The Center builds respect for whistleblowers as part of its business culture and provides them with conditions for reporting possible facts of corruption or corruption-related offenses, other violations of the Law (hereinafter referred to as Reports), in particular, by:

1) making Reports through the Unified Whistleblower Reporting Portal and other channels, including anonymously;

 2) determination, in accordance with the Law, of internal procedures and mechanisms for accepting and considering Reports, verifying and appropriately responding to them;

3) providing methodological assistance and consultations on the implementation of the Notification to potential whistleblowers;

4) compliance with the rights and guarantees of protection of whistleblowers.

6.7.2. Information about channels and methods of making Notifications must be brought to the attention of the staff, representatives of the Center, persons performing certain work on the basis of civil law contracts concluded with the Center, and business partners of the Center.

7. Control over compliance with the requirements of the Policy and disciplinary liability for their violation 

7.1. The Commissioner shall constantly monitor compliance with the requirements of this Policy by:

1) consideration and response to the Notification;

2) conducting approval of draft agreements or other documents aimed at implementing 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 may be determined by the Director of the Center based on the proposals of the Commissioner (procedure for conducting scheduled and unscheduled inspections of personnel activities; procedure for conducting inspections of the Center's documents, etc.).

7.2. If, during the monitoring of compliance with the requirements of this Policy, the Commissioner discovers signs of a corruption or corruption-related offense, he shall initiate disciplinary proceedings before the Director of the Center and participate in them.

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

7.4. The Human Resources and Administrative Support Department of the Center sends to the National Agency for the Prevention of Corruption a certified paper copy of the decision (order) of the Director of the Center on the imposition of disciplinary sanctions and an information card to the administrative document on the imposition (cancellation of the administrative document on the imposition) of disciplinary sanctions on a person for committing corruption or corruption-related offenses in order to enter information on the imposition of disciplinary sanctions for committing a corruption or corruption-related offense into the Unified State Register of Persons Who Committed Corruption or Corruption-related Offenses.

Commissioner for Anti-Corruption Robert SIVERS