Corruption Prevention Policy

Charitable Organisation "Charity Fund Name of Michael Vasylevsky" (USREOU 44317490; Ukraine, 02081, Kyiv, 23-A Urlovska St., Apartment 171)  (hereinafter referred to as the Fund) is guided by the principle of "zero tolerance" to any manifestations of corruption in its internal activities, as well as in its relations with donors, beneficiaries, contractors and regulatory authorities. In this Conflict of Interest and Corruption Prevention Policy, we describe the measures we take to prevent, detect and combat corruption and related practices in order to implement this principle.

 

Conflict of Interest and Corruption Prevention Policy

1.    The terms used in this Policy shall have the meaning given in the Law of Ukraine "On Prevention of Corruption", and other legislation of Ukraine regulating the application of preventive anti-corruption mechanisms, including international treaties ratified by the Verkhovna Rada of Ukraine.

2.    The Fund's contractors and partners shall be selected based on the results of the assessment of the transparency of their activities, the quality of goods, works and services, as well as their business reputation. Prior to establishing business relations, the Fund, represented by the President, shall verify if there is information in open sources that a potential partner or counterparty, their officers or officials have committed acts related to corruption, and shall take measures to find out whether a potential partner or counterparty will be used as an intermediary to transfer to third parties (or to receive from third parties) an unlawful benefit. If information is found on corruption-related actions or if there are grounds to assume that a potential partner or counterparty is being used to obtain an unlawful benefit by third parties, business relations shall not be established.

3.    The Fund ensures the development and implementation of measures that are necessary and sufficient to prevent, detect and combat corruption in its activities, in particular, by obliging persons acting on behalf of and/or in the interests of the Fund:

- when performing actions related to the consideration of requests received by the Fund from persons in need of charitable aid, refrain from demonstrating a personal attitude to political views, ideology, religion, or ethnicity of the person making the request

- refuse to accept gifts, services or financial remuneration from contractors, beneficiaries, partners or persons acting on their behalf;

- prevent the conclusion of contracts that provide for the Fund's obligation to transfer property (including money) with individuals who are members of their family or family members of other persons acting on behalf of and/or in the interests of the Fund, as well as with legal entities whose management or ultimate beneficial owners are members of their family or family members of other persons acting on behalf of and/or in the interests of the Fund. This restriction does not apply when such individuals or legal entities are the only possible suppliers of goods, works or services required by the interests of the persons applying to the Fund for aid. In this case, the Fund shall inform about the transfer of property and the reasons for purchasing goods, works, services from these persons on its website;

- not to disclose or otherwise use any restricted information that they have become aware of in connection with the performance of their functional duties unless otherwise provided by law;

- promptly inform the Fund, represented by the President, of any real or potential conflict of interest and not act in the context of a conflict of interest until a decision is made on its settlement;

- refrain from behaviour that may be regarded as a willingness to commit a corruption offence or inducement to commit a corruption offence;

- promptly inform the Fund, represented by the President, about known cases of corruption or corruption-related offences committed by persons acting on behalf of the Fund or individuals or legal entities with whom the Fund has or plans to have contractual relations.

4.    The Fund's governing bodies may carry out selective inspections of payments made to ensure compliance with the requirements of this Policy, as well as to verify their economic feasibility and expediency, including on the basis of primary accounting documents.