How do the compliance systems of the international companies work in Ukraine?

How do the compliance systems of the international companies work in Ukraine?

Elena Rybak, Managing Director of iC consulenten Ukraine, a UNIC member company, shared her experience at the "Anti-Corruption and Compliance" seminar, organized by the Advantage Austria in Ukraine with the support of ICC Austria, Advice Group, UNIC and Business Ombudsman Council held on 25 March 2019 in Kyiv:

"When company’s activity stipulates participation in tenders, then anti-corruption compliance system becomes crucial, said Elena Rybak. - Historically iC developed gradually, constantly moving forward, without sharp pikes in growth and drops down. That`s exactly why the team had been forming based on trust, growing step by step. This always gave confidence in employees as a team of responsible and decent people united with a common goal. There was no need in CMS establishment for years and this would last for a long time, if the situation with the World Bank hadn’t happened.

In 2014 one of iC group member company in one of the countries did a malpractice during a tender. As a result, iC was "blacklisted" for 6 months by the World Bank. However, April showers bring May flowers! "Blacklist" forced top-management of the company to review their attitude towards managing of the company and to establish CMS in 2015, which effectively works up to now. This system is a strong inspiring factor for the new employees, especially for those, who work in the Ukrainian office, taking into account the level of corruption in the country.

How does the compliance system work in iC consulenten?

CMS is applicable for all stakeholders: both employees, subcontractors and clients. Basic principles:

• Any misconducts must be reported to the compliance officer and business partners immediately
• All charitable donations, sponsorships or political contributions need a special review
• All business transactions and payments should be recorded in a comprehensive and transparent way
• No gifts, entertainment and hospitality, which may be deemed to improperly affect the outcome of a business transaction or otherwise result in an improper advantage
• No tolerance for any forms of misconduct fraudulent, corrupt, collusive, coercive or obstructive practices will not be tolerated in any way.

CMS tools in iC group

Responsible person: all possible misconducts must be reported to compliance-manager confidentially and anonymously – through the form at the web page.

Work with employees:

• Аll employees necessarily pass the compliance trainings.
• A special section with compliance statement is incorporated in all contracts with employees, subcontractors and clients.
• Special attention is given to the strict observance of the tender procedures – both to those where we directly participate, and to those we manage on behalf of the client.  

You can find some cases related to non-compliance and observed in our practices in the slides at the link: http://bit.do/eNsHg."