The 14th Anti-Corruption Compliance Program, which the Corporate Governance Professional Association has implemented since 2017 with the  Center for International Private Enterprise (CIPE) support, has been completed.

All participants successfully passed the exam, defended the final projects, and received certificates. Among the twenty-four participants of the Program were lawyers, compliance officers, security specialists. Considering quarantine restrictions and the participants’ wishes, the Program was held in a mixed format – half of the participants were present online.

The Program was started by Oleksandr Okuniev, Chairman of the CGPA Management Board. First, he defined the concept of compliance and anti-corruption compliance. Then, he explained the business’s competitive advantages with the implemented compliance policy and the legal regulation to prevent corruption in business. Finally, the day ended with a review of cases of anti-corruption investigations in Ukraine and abroad.

The second day of the Program was devoted to discussing the main elements of anti-corruption compliance with Olga Shenk, advisor to the international law firm CMS Cameron McKenna. In particular, the following issues were considered:

• Anti-corruption compliance and anti-corruption Program
• Gift and hospitality policy
• Politics in the field of charity and support of political parties
• Conflict of interest policy
• Work with staff (selection, testing, training, white and blacklists)

Internal investigations

At the end of the second day of the Program, Danylo Globa, Deputy Director of Legal Control at You-Control, shared with the participants approaches to understanding the concept of the “information footprint” of a company or individual can be and how to get rid of it.

Participants got acquainted with the capabilities of the YouControl portal and its tools for analyzing the companies and individual entrepreneurs.

Oleg Polishchuk, Member of the Board of the National Association of Anti-Corruption Compliance, Anti-Corruption Compliance Expert, Former Director for Prevention of Corruption – Adviser to the President of NNEGC “Energoatom”, shared with participants his own experience, talked about the authorized person’s interaction with regulators and law enforcement. O. Polishchuk singled out several tasks of the Commissioner, namely:

• The main tasks of the Commissioner are to prepare, ensure the implementation and control over the implementation of measures to prevent, combat, and detect corruption in the Legal Entity.
• The Commissioner exercises his rights and responsibilities directly. The Commissioner may involve other employees of the Legal Entity in the performance of their functions
• The Exercise of the Commissioner’s functions in the Legal Entity is independent. Interference in the activities of the Commissioner by employees, founders (participants), managers, business partners of the Legal Entity, as well as other persons is prohibited
• It is prohibited to impose on the Commissioner duties that do not belong to or go beyond his powers, defined by the Law and the Anti-Corruption Program, or limit the performance of his powers

Pavlo Verkhnyatsky, the founder and CEO of COSA, a partner of CGPA in implementing the Program, began to get acquainted with the main elements of the anti-corruption compliance of the participants.

Pavlo began his conversation with the participants on how to work with counterparties, namely the internal processing of third-party data, communication concerning the compliance issues, due diligence of third parties. The session ended with a review of corporate intelligence in the compliance system, namely its tools and methods.

Oleg Lagodiyenko, Director of Ethicontrol, discussed the approaches to corruption risk management, risk identification, and assessment and explained how to present the results in the form of a “risk register” and a “heat map”.

In addition, Oleg shared his experience in developing and implementing channels for consultations and reports of violations (“Hotline”), explained possible reactions to identified violations, and highlighted legislative innovations in Ukraine on the protection of whistleblowers the mechanism of confidential notification. The session ended with a practical lesson to analyze the “hotline” capabilities on the example of “Ethicontrol”.

Katya Lysova, Senior Program Officer, Europe & Eurasia, at the Center for International Private Enterprise (CIPE), shared with program participants the experience of implementing anti-corruption compliance programs in the United States, the requirements for them, each time emphasizing the changes being implemented by the US government. Separately, Katya singled out and talked about the work of CIPE in disseminating experience in implementing anti-corruption compliance and anti-corruption programs in different regions of the world among small and medium-sized businesses.

NACP for business: partner or controller? Serhiy Derkach, Head of the Department for Prevention and Detection of Corruption of the National Agency on Corruption Prevention, spoke about this with the participants.

The next Program is scheduled for November 1-5, 2021. Registration