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Four Years of NACP 2.0: Building Integrity in the Public and Private Spheres

We continue to summarize the four-year work of the current NACP 2.0 team. Thanks to the consistent work of the National Agency on Corruption Prevention (NACP), leaders of public and private organizations have received systematic tools to build integrity in their organizations.

"The system of anti-corruption compliance in organizations makes them honest and therefore effective. It also helps to increase public confidence in both anti-corruption measures and the activities of government institutions in general. Therefore, in recent years, the formation and implementation of integrity policy in the public and private spheres, in particular, the improvement of legal regulation in this area, have been among the priorities of the NACP," said Acting Head of the NACP, Iaroslav Liubchenko.

During 2020-2023, the NACP developed a regulatory framework for the activities of anti-corruption commissioners, including the Model Regulation on the Authorized Unit (Authorized Person) for the Prevention and Detection of Corruption, the Methodology for Corruption Risk Management, and the Model Anti-Corruption Program of a Legal Entity.

The NACP also approved the Methodology for Evaluating the Performance of Authorized Units (Authorized Persons) for the Prevention and Detection of Corruption, which defines the procedure, forms, and methods for evaluating the effectiveness of anti-corruption commissioners.

In 2021, the NACP presented the Integrity Portal (Anti-Corruption Portal), the first digital platform for the work of anti-corruption commissioners. At the end of 2023, it launched the module "Development of an Anti-Corruption Program." Authorized persons were able to create integrity programs (anti-corruption programs) for their own organizations online, with the help of which 5 organizations have already successfully prepared anti-corruption programs and another 10 are in the process of preparation.

The NACP provided systematic methodological assistance to local governments and established cooperation with specialized associations of local governments.

More than 20 local self-government bodies and two all-Ukrainian community associations joined the signing of the Building Integrity Declaration, a document based on the best practices of the Council of Europe on good governance and taking into account the provisions of the UN Convention against Corruption. The Declaration is intended to motivate community leaders to build a good governance system.

The NACP has developed guidelines for analyzing counterparties in local government procurement and conducted an analytical study on ethical behavior among deputies and elected officials in local governments.

Since 2020, after the amendments to the Law of Ukraine "On Prevention of Corruption" came into force, which introduced a new definition of the term "whistleblower," three types of reporting channels (internal, regular, and external) were introduced, and the list and scope of whistleblower rights guarantees were expanded. The NACP was actively involved in reviewing and analyzing cases related to whistleblower protection and developed a collection of procedural documents and recommendations that will be useful to a whistleblower when applying to the court for protection of their rights.

After the launch of the Unified Whistleblower Reporting Portal in 2023, the National Agency developed a Practical Guide on Working with Whistleblowers for authorized units (authorized persons) on corruption prevention and detection.

In 2023, the NACP developed "Guide for Top-managers: Building a Virtuous and Efficient Organization," a comprehensive practical document on the systematic development of integrity and effective organizations in the public and private sectors. It contains step-by-step recommendations for creating an effective organization, from assessing the current level of integrity and defining the mission and vision to appointing an anti-corruption commissioner, identifying corruption risks, approving an anti-corruption program (integrity program), and ensuring the independence of internal audit.

"We advocate the position that the CEO is the key person in building anti-corruption compliance in the organization and is directly responsible for whether the organization is honest. At the same time, we are convinced that the Anti-Corruption Commissioner, as the holder of the relevant powers and expertise, is the main ally and partner for the CEO. Effective interaction between the head and the commissioner is the key to the effective development and implementation of the departmental integrity policy. With this in mind, the National Agency continues to provide more and more new tools for both the head and the commissioner," said Yurii Sverba, Head of the Integrity Policy Development Department.

The analytical report on the NACP's work for four years (2020-2023) is available here.

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