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03.08.2020Compliance Officer Training Program has been successfully completed

On July 27-31, 2020, the Compliance Officer Training Program was successfully conducted. It began with the consideration of the concept of compliance. Most of the participants in the Program were representatives of banks and insurance companies (eight), the real sector (ten), namely the defense and oil refining industries, as well as several representatives of law firms (three), the telecommunications sector (one), and the state regulator – National Agency on Corruption Prevention (two).

Oleksandr Okuniev, Chairman of the CGPA Management Board, spoke about anti-corruption compliance and the competitive advantages of the business with the implemented compliance policy. The legal regulation of the prevention of corruption in business was considered separately. It was interesting for the participants to review the cases of anti-corruption investigations in Ukraine and abroad.

Oleg Boyko, an Independent Consultant on Corporate Governance, Risk Management and Compliance (GRC), told the participants about the implementation of anti-corruption measures in organizations, including:

  • The concept of an organization, the model of organization;
  • The place and role of anti-corruption compliance in the organization, the model of three lines of defense;
  • A career in anti-corruption compliance;
  • Anti-corruption compliance as a business process: ISO 37001, COSO-I, recommendations of international organizations.

Corporate culture and the code of ethics were also considered separately.

The key to the success of the Commissioner for Anti-Corruption Measures is the ability to establish useful interaction with the “owners” of other processes in the company, which in one way or another are intertwined with the process of anti-corruption compliance,” O. Boyko said.

 Pavlo Verkhnyatsky, Founder and CEO of COSA, focused the participants on the following issues:

  • Anti-corruption inspection of contractors
  • Corporate intelligence in the compliance system (compliance in current geopolitical conditions, compliance as a defining component of corporate security, tools, and methods of corporate intelligence in the compliance system).

In his presentation, Pavlo gave many examples of dishonesty that could affect a company, sometimes very unpredictable circumstances that would never have occurred in other conditions.

 YouControl Customer Support Specialist Zhanna Pilkevych told the Program participants about the benefits of the YouControl system to compliance officers. Zhanna told about the features of the search program, novelties, shared interesting observations and research, as well as life hacks in working with the resource.

Olga Shenk, Counselor, CMS Dispute Resolution and Compliance Coordinator, Cameron McKenna Nabarro Olswang, continued the conversation with the Program participants about the main elements of anti-corruption compliance, namely:

  • made a comparison and analysis of anti-corruption compliance and anti-corruption program;
  • shared engaging experiences in interpreting gift and hospitality policies;
  • noted the peculiarities of policies in the field of charity and support of political parties;
  • singled out policies in the area of conflict of interest;
  • told about working with staff (selection, testing, training, white and blacklists);
  • finally said about the rules of internal investigations.

On the third day of the Program, O. Boyko worked with the participants on the issue of corruption risk management. In particular, the following items were considered:

  • Identification and assessment of risks;
  • Presentation of results in the form of “risk register” and “heat map”;
  • Analysis of results;
  • Setting an example of a high-risk situation and actions to address it.

The participants were given the task to act out a scene of application of risk management methods by the compliance officer or the compliance service of the company, which they successfully and with pleasure done.

 Oleg Lagodiyenko, Director of Ethicontrol, continued to tell the participants about the main elements of anti-corruption compliance. Oleg drew the participants’ attention to the channels for consultations and reports of violations, namely the hotline; separately, he dwelled on the features and widespread reactions to the identified violations. Finally, he reported on legislative innovations in Ukraine regarding the protection of whistleblowers and the mechanism of confidential communication.

Options for determining the level of trust in the hotline:

  • Availability of key units (e.g., Headquarters or Security Service) and senior management among the participants in the communications;
  • Presence of complex cases (e.g., corruption or kickbacks);
  • The share of anonymous cases – the smaller – the worse. Landmark – from 10%;
  • Positive anonymous feedback from informants on the results of the response.

Katya Lysova, Eurasia Program Manager at the Center for International Private Enterprise (CIPE, Washington), presented the participants with updated requirements for anti-corruption compliance programs. Katya shared the foreign practice of developing and conducting such programs, which is worth paying attention to and what you can not do without in any case.

Serhiy Derkach, Head of the Department for Prevention and Detection of Corruption of the National Agency on Corruption Prevention (NACP), told the participants about the state and priority areas of work of the National Agency on Corruption Prevention. Also, the speaker focused on the priorities in the work of his department; he told about the anti-corruption portal and the opportunities it provides. The issue of the institution of whistleblowers, its regulation, and protection provoked a lively discussion.

All 24 participants of the Program successfully passed the test and presented final group work, as a result of which they received Certificates.