ANTI-CORRUPTION POLICY
CHARITABLE ORGANIZATION «CHARITABLE FOUNDATION «ISKRA VOLY»

(Approved by Resolution of the Supervisory Board No. ____ of ________)

Preamble

With this Anti-corruption policy, CHARITABLE ORGANIZATION «CHARITABLE FOUNDATION «ISKRA VOLY» (hereinafter – “ISKRA VOLY”) declares that all its employees, officials, managers, founders and board members (participants) in their internal activities, as well as in their legal relations with their partners, state authorities, local self-government bodies, other legal entities and beneficiaries of the project (host families and IDPs) are guided by the principle of "zero tolerance" to any manifestations of corruption and will take all measures provided for by law to prevent, detect and counter corruption and actions (practices) related to it.

I. General provisions

1. The anti-corruption policy is a set of rules, standards and procedures for detecting, countering and preventing corruption in the activities of ISKRA VOLY.

2. The anti-corruption policy establishes standards and requirements no lower than those stipulated Law of Ukraine "On the Prevention of Corruption" (hereinafter - the “Law”) and the Model Anti-Corruption Program, approved by the decision of the National Agency for the Prevention of Corruption.

3. Terms in the Anti-Corruption Policy are used in the meanings given in the Law.

4. The text of the Anti-corruption policy is permanently available to employees and officials of ISKRA VOLY, as well as to its partners, any legal entities and individuals.

II. Scope of the Anti-corruption Policy

1. The anti-corruption policy is mandatory for all employees of ISKRA VOLY, including officials of all levels, managers, founders (participants), for all persons who are in labor relations with ISKRA VOLY, as well as volunteers, hosts and IDPs.

2. The anti-corruption policy is also applied by ISKRA VOLY in its legal relations with partners, including state authorities and local self-government bodies, other legal entities and individuals.

3. Implementation of measures for the implementation (implementation) of the Anti-corruption Policy within the limits of their powers shall be carried out by:

1) founders (participants) of ISKRA VOLY (hereinafter – the “founders (participants)”;

2) Head of the Board of Directors of ISKRA VOLY (hereinafter - the “head”);

III. Anti-corruption measures in the activities of ISKRA VOLY

1. List of anti-corruption measures in the activities of ISKRA VOLY

1. ISKRA VOLY ensures the development and implementation of measures that are necessary and sufficient to prevent, detect and counter corruption in its activities.

2. Anti-corruption measures include:

1) periodic assessment of corruption risks in the activities of ISKRA VOLY;

2) anti-corruption standards and procedures in the activities of ISKRA VOLY.

3. The main anti-corruption standards and procedures of ISKRA VOLY are:

1) familiarization of all employees with the content of the Anti-corruption policy and signature of a code of conduct for employees and volunteers conducting sensitization and trainings on corruption, and how to prevention, address and counter corruption;

2) criteria for selecting partners and their anti-corruption check;

3) inclusion of provisions on mandatory compliance with the Anti-corruption Policy in the documents issued by ISKRA VOLY;

4) restrictions on the support of political parties and movements of the ISKRA VOLY;

5) norms of professional ethics and obligations and prohibitions for employees;

6) restrictions on gifts;

7) performance by employees of functions related to the prevention of corruption;

2. Timely assessment of corruption risks in the activities of the ISKRA VOLY

1. ISKRA VOLY conducts an internal assessment of corruption risks in its activities at least once a year.

2. Corruption risk is a justified probability of the occurrence of a corrupt or corruption-related offense or a violation of the requirements of the Anti-Corruption Policy.

3. The assessment of corruption risks in ISKRA VOLY is carried out by the manager.

To assess corruption risks, other employees of ISKRA VOLY, as well as independent experts or specialists, may be involved.

4. The purpose of the assessment of corruption risks is to prevent, identify and eliminate corruption risks in the activities of the founders (participants), manager and employees of ISKRA VOLY.

5. Corruption risks in the activities of ISKRA VOLY are divided into internal and external.

Internal corruption risks are identified in the organizational-management, financial-economic, personnel, and legal procedures of the ISKRA VOLY.

External corruption risks are identified in the activities of partners, including state authorities, local self-government bodies, with which ISKRA VOLY has a legal relationship.

6. According to the results of the identification of corruption risks, their definition and description, classification by categories and types are carried out.

7. Based on the results of the assessment of corruption risks in the activities of the ISKRA VOLY, a written report is prepared, which must contain:

1) identified corruption risks, as well as the reasons that give rise to them and the conditions that contribute to them;

2) assessment of identified corruption risks;

3) proposals for measures to prevent, eliminate (reduce) the level of identified corruption risks.

The text of the report is provided for review by employees of ISKRA VOLY, and may also be made public on the website of ISKRA VOLY.

8. If, during measures to assess corruption risks, the manager discovers a violation of the Anti-Corruption Policy, the commission of a corruption or corruption-related offense, he conducts an internal investigation.

9. Based on the results of the corruption risk assessment report, the manager, founders (participants) take the necessary measures to prevent, detect and counter corruption in the activities of ISKRA VOLY, including by changing the existing anti-corruption standards and procedures.

3. Description of anti-corruption standards and procedure of the ISKRA VOLY

1. In order to form an appropriate level of anti-corruption culture by the manager for new employees, as well as other persons acting on behalf of ISKRA VOLY (including volunteers), a mandatory introduction to the provisions of the Law, the Anti-Corruption Policy and related documents.

2. Provisions regarding the obligation to comply with the Anti-corruption Policy are included in the rules of the internal labor regulations of ISKRA VOLY, all labor contracts/contracts, and may also be included in the contracts concluded by ISKRA VOLY.

3. Partners of ISKRA VOLY are selected according to criteria based on transparency of activity, competitiveness, quality of goods, works and services, and reliability.

4. The manager conducts an anti-corruption audit of existing or potential partners of ISKRA VOLY in order to assess the presence of corruption risks. At the same time, the Manager checks whether the business partner has the reputation of an entity whose activities are related to corruption (even in the absence of relevant court decisions), and whether the business partner will not be used as an intermediary for transferring to third parties (or for receiving from third parties) of undue benefit.

anti-corruption inspection is carried out in accordance with the requirements of the Anti-Corruption Policy, as well as the standards of activity of the ISKRA VOLY.

In the case of a negative recommendation, the manager must make a reasoned decision on this issue in order to continue or start legal relations with such a partner.

5. It is not allowed to carry out charitable activities of ISKRA VOLY if:

1) its implementation is a condition for concluding any contract, making a decision by a state authority, a local self-government body, or is carried out for the purpose of obtaining advantages in business activity;

2) a partner or a state authority, a local self-government body insists on carrying out one or another type of charitable activity through a certain non-governmental organization.

6. ISKRA VOLY cannot make contributions to support political parties and movements.

IV. Standards of professional ethics of employees and volunteers of ISKRA VOLY

1. Employees and volunteers of ISKRA VOLY during the performance of their functional duties are obliged to strictly adhere to generally recognized ethical norms of behavior.

2. Employees and volunteers of ISKRA VOLY are tolerant and respectful of the political views, ideological and religious beliefs of others, and also undertake not to use their powers in the interests of political parties and movements.

3. Employees and volunteers of ISKRA VOLY act objectively, regardless of personal interests, personal attitude towards any persons, their political views, ideological, religious or other personal views or beliefs.

4. Employees and volunteers of ISKRA VOLY conscientiously, competently, on time, effectively and responsibly perform functional duties, decisions and assignments of bodies and officials to whom they are subordinate, accountable or under control, and also do not allow abuses and inefficient use of funds and property of ISKRA VOLY.

5. Employees of ISKRA VOLY do not disclose or use in any other way confidential information that has become known to them in connection with the performance of their functional duties, except for cases established by law.

6. Employees of ISKRA VOLY, regardless of their personal interests, refrain from implementing decisions or instructions of the management of ISKRA VOLY, if they pose a threat to the legally protected rights, freedoms or interests of individual citizens, legal entities, state or public interest or contrary to the law.

7. The employees of ISKRA VOLY independently assess the legality of the decisions or orders given by the management and the possible damage that will be caused in the event of the implementation of such decisions or orders.

In the case of receiving decisions or instructions for the execution of which an employee of ISKRA VOLY considers to be illegal or which pose a threat to the rights, freedoms or interests of individual citizens, legal entities, state or public interests protected by law, he must immediately in writing to notify the head of ISKRA VOLY, or its founders (participants).

V. Rights and obligations of employees of ISKRA VOLY

1. Heads of the ISKRA VOLY, its employees, volunteers and other persons acting on behalf of the ISKRA VOLY have the right to:

1) provide proposals for improving the Anti-corruption Policy;

2) receive consultations on the implementation of the Anti-corruption Policy and clarifications on its provisions.

2. The managers of the ISKRA VOLY, its employees and volunteers are obliged to:

1) comply with the relevant requirements of the Law, the Anti-Corruption Policy and related internal documents, as well as ensure the practical implementation of the Anti-Corruption Policy;

2) perform their immediate duties taking into account the purpose of the activity of ISKRA VOLY;

3) to immediately inform the head or founders (participants) of ISKRA VOLY about cases of violation of the requirements of the Anti-Corruption Policy (or cases of incitement to such actions), corruption or corruption-related offenses by other employees of ISKRA VOLY or other natural or legal persons with whom ISKRA VOLY is or plans to be in relations;

4) to inform urgently, in accordance with the procedure specified by the Anti-corruption Policy, about the occurrence of a real, potential conflict of interests;

5) to refrain from behavior that can be regarded as readiness to commit a corruption offense related to the activities of ISKRA VOLY;

6) not to commit and not to participate in the commission of corruption offenses related to the activities of ISKRA VOLY.

3. The employees and the manager of ISKRA VOLY are prohibited from:

1) use one's official authority or one's position and related opportunities in order to obtain an unlawful benefit for oneself or other persons;

2) use any property of ISKRA VOLY or its funds in private interests;

3) demand or receive any material or non-material benefit (for oneself or for close persons) in connection with the performance of one's official duties, which is not provided for labor or other contract between them and ISKRA VOLY;

4) organize, act as an intermediary or personally make any cash or non-cash payments or settlements with business partners of ISKRA VOLY, if such payments or settlements are not provided for by current legislation;

5) to directly or indirectly influence the decisions of the employees of ISKRA VOLY for the purpose of obtaining any material or non-material benefit for themselves or for their relatives, which is not provided for in the employment or other contract between them and ISKRA VOLY;

6) commit any actions that directly or indirectly incite other employees, the head of ISKRA VOLY to violate the requirements of the Law or the Anti-corruption Policy.

7) pay ransom, bribe or other incentives.

4. After dismissal or other termination of cooperation with ISKRA VOLY, a person is prohibited from disclosing or using in another way in his own interests (confidential) information that became known to him in connection with the performance of his powers, contractual obligations, except for cases established by law.

5. Demanding, requesting, receiving gifts for oneself or third parties from legal entities or individuals by employees, managers of ISKRA VOLY (directly or through other persons) in connection with the performance of their powers or their position and related with these possibilities are not allowed.

Employees, volunteers, the manager may accept gifts that correspond to generally accepted notions of hospitality (for example, gifts in the form of souvenirs, treats with food and drinks, invitations to entertainment events, reimbursement of transportation expenses and hotel accommodation), except for the cases provided for in clause 5 of this section, if the value of such gifts does not exceed one subsistence minimum for able-bodied persons, established on the day of acceptance of the gift, once, and the aggregate value of such gifts received from one person (group of persons) during the year does not exceed two subsistence minimums established for able-bodied persons persons on January 1 of the year in which the gifts are accepted.

The limit on the value of gifts provided by this clause does not apply to gifts that:

are given by loved ones;

are received as publicly available discounts on goods, services, publicly available winnings, prizes, bonuses, bonuses.

In case of discovery of a gift, in respect of which there is a ban on its receipt, in the office premises, as well as in case of receipt of a gift offer, employees, volunteers, head of ISKRA VOLY are obliged to immediately, but no later than one working day, take such activities:

1) refuse the offer;

2) if possible, identify the person who made the offer;

3) attract witnesses, if possible, including among the employees of ISKRA VOLY;

4) to inform in writing about the proposal of the manager of ISKRA VOLY.

An act is drawn up on the discovery of property that may be an illegal benefit or a gift, which is signed by the person who discovered the illegal benefit or gift, and by the head of ISKRA VOLY or a person authorized to perform his duties.

6. Employees, managers, as well as persons acting on behalf of ISKRA VOLY shall refrain from offering gifts to civil servants, people's deputies of Ukraine, deputies of local councils, their relatives, actual or potential business partners, their employees or representatives, as well as from any other behavior that can be regarded as readiness to commit a corruption offense related to the activities of ISKRA VOLY.

Gifts may be permitted where appropriate generally recognized notions of hospitality and their value does not exceed the legally established amounts.

The general policy of ISKRA VOLY regarding offers of gifts on behalf of ISKRA VOLY within the framework of generally recognized notions of hospitality is determined by the manager, taking into account the requirements of the law.

VI. The procedure for supervision, monitoring of compliance with the Anti-corruption program, as well as evaluation of the results of implementation of the measures provided for by it

1. The manager supervises and constantly monitors compliance by employees and volunteers of ISKRA VOLY with the Anti-corruption Policy.

2. Supervision and control over compliance with the Anti-corruption Policy is carried out in the following forms:

1) consideration and response to reports of violations of the requirements of the Anti-corruption Policy, commission of corruption or corruption-related offenses;

2) carrying out an internal assessment of corruption risks in one's activity;

3) examination of organizational and administrative, legal and financial documents, as well as their projects.

3. If, during supervision or monitoring of compliance with the Anti-Corruption Policy, the manager detects signs of a violation of the Anti-Corruption Policy or signs commission of a corruption or corruption-related offense, he conducts an internal investigation in accordance with the procedure provided for in Chapter XI of the Anti-Corruption Policy.

VII. Confidentiality conditions for informing employees about the facts of violations of anti-corruption requirements

1. Employees of ISKRA VOLY are guaranteed the confidentiality of their reports to the founders (participants), the manager about detected signs of violations of the Anti-Corruption Policy, corruption or corruption-related offenses in the activities of other employees of ISKRA VOLY, and reports about facts inciting employees of ISKRA VOLY to commit corruption or corruption-related offenses.

2. Notifications of detected signs of violations of the Anti-Corruption Policy, as well as notifications of facts of incitement of employees of ISKRA VOLY to commit corruption or corruption-related offenses can be made orally or in writing, using communication channels, defined in the Anti-Corruption Policy.

Notifications can also be made by employees and officials of business partners of ISKRA VOLY.

3. Submission of knowingly false messages is not allowed.

4. Reports of employees of ISKRA VOLY about the detection of signs of corruption or corruption-related offenses may be anonymous.

Anonymous report on detection of signs of corruption or related to corruption offenses can be considered only in the event that the information provided in it relates to a specific employee of ISKRA VOLY or business partners of ISKRA VOLY and contains factual data that can be verified.

5. The manager or a person authorized by the manager or the founders (participants) shall verify the information contained in the message.

6. Any data that makes it possible to identify the person who reported the facts of incitement to commit a corruption or corruption-related offense or the detection of signs of violation of the requirements of the Anti-Corruption Policy, the commission of corruption or corruption-related offenses by employees or other persons , belong to confidential information and are protected in accordance with the law.

The persons involved in the verification of the information contained in the message do not have the right to disclose it.

VIII. Procedures for the protection of employees who reported information about a corruption or corruption-related offence

1. The head, within the limits of his authority, provides conditions for the protection of persons who provide assistance in preventing, detecting and countering corruption in the ISKRA VOLY.

2. Information about an employee who reported signs of violation of the requirements of the Anti-Corruption Policy, detection of signs of a corruption or corruption-related offense (hereinafter – the “whistleblower”) may not be disclosed, except in cases established by law.

3. The whistleblower may not be fired or forced to fire, brought to disciplinary action, or subjected to other negative measures of influence by the management (transfer, certification, change of working conditions, refusal to be appointed to a higher position, salary reduction, etc.) or the threat of such measures influence in connection with his notification of a violation of the requirements of the anti-corruption legislation and/or the requirements of the Anti-corruption Policy.

4. In the event of a leak of confidential information about the whistleblower, the head of ISKRA VOLY shall immediately take all measures to avoid negative consequences for the whistleblower associated with such disclosure.

IX. Settlement of conflict of interests in the activities of employees of ISKRA VOLY

1. Employees of ISKRA VOLY are obliged no later than the next working day from the date when they learned or should have learned about the existence of a real or potential conflict of interests, to notify their immediate supervisor in writing, not to take actions and not make decisions in conditions of real conflict of interest and take measures to resolve real or potential conflict of interest.

In the event of a real or potential conflict of interest, the head of ISKRA VOLY shall notify the founders (participants) thereof in writing.

2. Within two working days after receiving a notification about the existence of a real or potential conflict of interest in a person subordinate to him, the manager makes a decision on the method of settling the conflict of interest, which he informs the employee about and uses measures provided for by law to prevent and resolve conflicts of interest (including in the case of self-identification of an existing conflict of interests in a person subordinate to him without making a corresponding notification).

3. The conflict of interests is resolved using one of the following measures:

1) removal of an employee from performing a task, performing actions, making a decision or participating in its adoption;

2) establishment of additional control over the employee's performance of the relevant task, his performance of certain actions or decision-making;

3) restrictions on employee access to certain information;

4) revision of the scope of the employee's functional duties;

5) transfer of the employee to another position;

6) dismissal of the employee.

4. The decision on the settlement of the conflict of interests in the activities of the head of ISKRA VOLY is made by the founders (participants).

5. Employees of ISKRA VOLY can independently take measures to resolve the conflict of interests by removing the relevant private interest and providing supporting documents to the manager. Deprivation of private interest should exclude any possibility of its concealment.

X. Application of disciplinary measures to employees who violate the provisions of the Anti-corruption Policy

1. In the event of information indicating signs of violation by employees of the requirements of the Anti-Corruption Policy, the following measures are taken:

1) an internal investigation is appointed in accordance with the procedure established by Chapter XI of the Anti-corruption Policy in order to confirm or refute information about an alleged violation;

2) if there are sufficient grounds based on the results of an internal investigation, the manager imposes a disciplinary penalty in accordance with the law.

2. Disciplinary sanctions are imposed by the manager on employees of ISKRA VOLY in accordance with labor legislation.

XI. The procedure for conducting internal investigations

1. In case of notification or signs of a violation of the Anti-Corruption Policy by an employee of ISKRA VOLY or signs of corruption or corruption-related offenses committed by an employee of ISKRA VOLY, the manager shall take the measures provided for in clause 2 of this section.

In the case of receiving a notification or detecting signs of a violation of the requirements of the Anti-Corruption Policy by the manager or signs of his committing a corruption or corruption-related offense, the founders (participants) shall take the measures provided for in Clause 2 of this section.

2. Under the conditions stipulated in paragraph 1 of this section, the founders (participants), the manager are obliged to take the following measures:

1) conduct an internal investigation in order to confirm or refute information about an alleged violation of the Anti-Corruption Policy or a corruption or corruption-related offense;

2) based on the results of the internal investigation, apply disciplinary sanctions to guilty persons, if there are grounds for this;

3) based on the results of the internal investigation, determine ways to eliminate the causes and consequences of the violation, if it occurred, as well as provide measures to prevent such actions in the future;

4) in the case of detection of signs of a corruption or corruption-related offence, for the commission of which administrative or criminal liability is provided, to immediately inform the specially authorized subjects in the field of anti-corruption.

3. An internal investigation is conducted only in cases where the provided or discovered information relates to specific persons and contains factual data that can be verified.

The term of the investigation should not exceed seven days.

The materials of internal investigations are kept in the archives of the ISKRA VOLY Financial Institution for at least 5 years.

Contacts

Ukraine, 01033
Kyiv, Tarasivska street, building 9-V
CHARITABLE ORGANIZATION “ISKRA VOLY” CHARITABLE FOUNDATION”

Identification code 44678496

Chairman of the Foundation - Sergii DAVYDENKO

Extract from the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations

Date and entry number in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations
27.07.2022 , 1000681070002063449

Activity types
88.99 Other social work activities without accommodation, n.e.c


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