Anti-Corruption Programme Development
Anti-corruption programme development is for companies that take part in public procurement or fall under the requirements of the Law of Ukraine “On Prevention of Corruption”, and for non-profit organisations whose donors require an anti-corruption policy, a conflict of interest policy and a whistleblowing mechanism. MK Audit has prepared such documents for more than 20 years, alongside financial policies for NGOs and businesses.
What you receive is not a formal text but a working set of documents: the programme or policy, a corruption risk assessment specific to your organisation, procedures for procurement, conflicts of interest and gifts, reporting and declaration forms, and staff training. We prepare the documents in Ukrainian and English so that they can be submitted to a donor or a foreign partner.
What is included
- corruption risk assessment: analysis of procurement, recruitment, work with contractors and beneficiaries, and payments;
- drafting of an anti-corruption programme under the law or an anti-corruption policy under donor requirements;
- conflict of interest policy and declarations for staff, board members and procurement committees;
- policy on gifts, hospitality and dealings with public authorities;
- whistleblowing procedure, protection of whistleblowers, internal investigation procedure;
- regulation on the compliance officer responsible for preventing corruption, with rights, duties and reporting lines;
- anti-corruption clauses for contracts with contractors, suppliers and sub-grantees;
- training for staff and management, with materials for annual refreshers;
- implementation and monitoring plan, review of the programme once a year or on changes.
Two approaches depending on who requires the document
| Criterion | Programme under the law | Policy under donor requirements |
|---|---|---|
| For whom | State-owned and municipal enterprises, participants in public procurement | NGOs, charitable foundations, recipients of grants and sub-grants |
| Basis | Law “On Prevention of Corruption”, model programme of the National Agency on Corruption Prevention | Donor rules: code of conduct, anti-fraud policy, conflict of interest |
| Approval | After discussion with employees, by order of the director | By decision of the board or director, with staff acknowledgement signatures |
| Language | Ukrainian | Ukrainian and English |
Who needs it
- NGOs, charitable foundations and donor-funded projects: an anti-corruption and anti-fraud policy is a standard condition of grant agreements, and its absence is recorded as a finding during a grant audit;
- organisations that pass funds on to sub-grantees and must require similar policies from them;
- LLCs and companies that take part in public procurement and must have an approved anti-corruption programme;
- state-owned and municipal enterprises, for which the programme is mandatory by law;
- representative offices and subsidiaries of foreign groups that need to adapt a global policy to Ukrainian law.
How the work proceeds
- Request and proposal. You tell us who requires the document (the law, a donor, a partner) and how your organisation is structured, and we send a commercial proposal within 1 day.
- Contract and checklist. We sign the contract, agree the timeline and send a list of documents and questions for the risk assessment.
- Execution. We interview management and key staff, assess the risks, prepare draft documents and agree them with you.
- Result and support. We deliver the final documents, train your staff and advise during approval and the first donor review.
Documents you will need
- charter, organisational structure, staffing table;
- existing internal policies: financial, procurement, HR, code of ethics, if any;
- grant agreements and donor requirements for policies;
- standard contracts with contractors, suppliers and sub-grantees;
- information on participation in public procurement and state programmes;
- results of previous audits or reviews with findings on policies.
Timing
An anti-corruption policy for a small NGO is ready in 1 to 2 weeks. A full programme with a risk assessment, a set of procedures and training for a company takes 3 to 5 weeks. If the donor has set a deadline, we work to an agreed schedule.
To find out when a programme is mandatory by law and what it must contain, see the page on the corporate anti-corruption programme. The existence and application of policies is checked during a grant audit, and day-to-day compliance is easier to control as part of our accounting services for NGOs and business.
Leave a request in the form below: we send a commercial proposal after reviewing the task and reply within 1 day.
Can we just adopt the model programme of the National Agency on Corruption Prevention?
The model programme is the basis for state-owned and municipal enterprises, but it must be adapted to the organisation’s processes. For donors, the model programme does not replace an anti-corruption policy with their mandatory elements.
Which policies do donors usually require?
Most often: an anti-corruption or anti-fraud policy, a conflict of interest policy, a code of conduct, a whistleblowing procedure and a procurement policy. We prepare them as a single consistent package.
Do we need to train our staff?
Yes. Both the law and donors expect staff to know the policy and how to report a violation. We deliver the training and hand over materials for annual refreshers.
Do you prepare the documents in English?
Yes. Policies for donors and international partners are prepared in two languages, Ukrainian and English.