Approved by the order № НУ/99/2023 dated 08.06.2023 "On approval of the Anti-Corruption Program of Igor Sikorsky Kyiv Polytechnic Institute" and the decision of the Conference of the labor collective dated April 20, 2023

Contents

Preamble (values)

I. General provisions

II. Rights, obligations, prohibitions

III. Legal status of the Commissioner and his/her subordinate employees

IV. Management of corruption risks

V. Educational activities

VI. Prevention and verification measures

VII. Notifications, their verification and responsibility

VIII. Supervision, control, amendments to this Program

Preamble (values)

With this Anti-Corruption Program (hereinafter referred to as the Program), the National Technical University of Ukraine "Igor Sikorsky Kyiv Polytechnic Institute" (hereinafter referred to as the University), realizing its responsibility for promoting the values of the rule of law and integrity, striving to ensure its sustainable development, taking care of its own business reputation, to encourage the use of good practices, and in the interests, in particular, but not exclusively, of its founders, employees, business partners clients, declares that its founders, rector, vice-rectors and heads of structural units, officials and employees in their activities, as well as in legal relations with business partners, public authorities, local governments, other legal entities and individuals are guided by the principle of zero tolerance to corruption in any of its forms and manifestations and take (will take) all measures to prevent, detect and combat corruption provided for by law and this Program.

The University declares its principled position and condemns corruption as an illegal and unethical way of doing business.

I. General provisions

1.Definition of terms

1.1. In this Program, the following terms are used in the following meanings:

charitable activity - voluntary personal and/or property assistance aimed at promoting the legitimate interests of the recipients of charitable assistance in the areas of charitable activity determined by law, which does not provide for the University to make a profit, as well as the payment of any remuneration or compensation to the University on behalf of or on behalf of the recipient of charitable assistance;

business hospitality - representative events (for example, business breakfasts, lunches, dinners, receptions, tastings, other events (conferences, cultural and sporting events)), reimbursement of travel, accommodation, other types of expenses that may be made by or in relation to the University for the purpose of establishing or establishing business relations or for other purposes related to the activities of the University;

relations between the University and legal entities and/or individuals related to the professional or economic activities of the University, which arose on the basis of a transaction or other activities of the University and provide for the duration of existence after their establishment;

business partners - legal entities and/or individuals with whom the University maintains, enters or intends to enter into business relations;

incentive payments - unofficial and illegal payments to officials in order to facilitate/accelerate/simplify or, in certain cases, properly perform procedures established by law, which the University has the legal right to receive without making such payments;

corruption risk - the likelihood of committing a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption", which will adversely affect the activities of the University;

unlawful benefit - money or other property, advantages, benefits, services, intangible assets, any other benefits of an intangible or non-monetary nature that are offered, promised, provided or received without legal grounds;

zero tolerance to corruption - absolute intolerance to corruption in any of its manifestations;

representative of the University - a person authorized in accordance with the established procedure to act on behalf of or in the interests of the University in relations with third parties;

official:

  • a person authorized to perform the functions of the state or local self-government in accordance with paragraph 1 of part one of Article 3 of the Law of Ukraine "On Prevention of Corruption";
  • a person who is equated to persons authorized to perform the functions of the state or local self-government in accordance with clause 2 of part one of Article 3 of the Law of Ukraine "On Prevention of Corruption";
  • employee of the patronage service in accordance with Article 92 of the Law of Ukraine "On Civil Service";
  • a candidate for the post of President of Ukraine and a candidate for the post of People's Deputy of Ukraine registered in accordance with the procedure established by law;
  • official of a foreign state (a person holding a position in a legislative, executive or judicial body of a foreign state, including jurors; other person performing state functions for a foreign state, in particular for a state body or state enterprise);
  • a foreign arbitrator, a person authorized to resolve civil, commercial or labor disputes in a foreign country in a procedure alternative to court proceedings;
  • an official of an international organization (an employee of an international organization or any other person authorized by such organization to act on its behalf);
  • member of an international parliamentary assembly to which Ukraine is a member;
  • judge and official of an international court;
  • sponsorship - voluntary material, financial, organizational and other support by the University of any event or activity in order to popularize the name of the University, trademarks for goods and services of the University.

1.2. Other terms in this Program are used in the meanings given in the Law of Ukraine "On Prevention of Corruption".

2. Purpose and scope of application

2.1. The purpose of this Program is to ensure the functioning of an effective system of preventing and combating corruption, compliance of the University with the requirements of anti-corruption legislation, taking into account the best world practices.

2.2. This Program establishes a set of measures (rules, standards and procedures) to prevent, detect and combat corruption in the activities of the University, not less in scope and content than provided by the Law of Ukraine "On Prevention of Corruption" and the Model Anti-Corruption Program of a legal entity, approved by Order No. 794/21 of the National Agency for the Prevention of Corruption dated 10.12.2021.

2.3. Measures to prevent, detect and eliminate or minimize corruption risks are recognized as a priority in the activities of the University.

2.4. This Program is mandatory for the Rector of the University, vice-rectors, heads of structural units, employees, representatives of the University and persons who are trained at the University or perform certain work on the basis of civil law contracts concluded with the University.

2.5. This Program is mandatory for all structural subdivisions, including the Slavutych Branch, the State Polytechnic Museum and the Institute of Special Communications and Information Protection.

2.6. This Program is applied in all areas of the University's activities, in particular in relations with business partners, officials, state and local authorities, other legal entities and individuals.

2.7. Provisions on the mandatory observance and implementation of this Program shall be included in the internal labor regulations of the University, regulations on structural units, all employment agreements, including contracts and job descriptions.

2.8. This Program is approved by the decision of the Conference of the labor collective and put into effect by the order of the Rector of the University after its public discussion.

2.9. The text of this Program is available in permanent open access for employees, representatives of the University, as well as for its business partners.

3. Responsible Leadership, Business Reputation and Integrity

3.1. Rector, vice-rectors and heads of structural subdivisions of all levels of the University undertake to form zero tolerance to corruption among employees and students of the University by personal example of ethical behavior, which is the basis of business culture, daily business practice and business reputation of the University.

3.2. The Rector, vice-rectors and heads of structural subdivisions of the University undertake to demonstrate leadership and responsibility with regard to:

1) compliance with the requirements of anti-corruption legislation;

2) ensuring the proper implementation, effective functioning, periodic analysis, timely review and improvement of the system of preventing and combating corruption at the University in order to properly respond to corruption risks in the University's activities;

3) spreading a culture of zero tolerance to corruption in all areas of the University's activities;

4) appointing a person responsible for the implementation of this Program (hereinafter referred to as the Commissioner), providing him/her with appropriate material and organizational working conditions, facilitating the performance of the tasks and functions provided for by the Law of Ukraine "On Prevention of Corruption" and this Program, ensuring the independence of the Commissioner's activities;

5) encouraging officials at all levels to demonstrate leadership in preventing and combating corruption within their authority;

6) directing employees to support the anti-corruption policy of the University and making a personal contribution to the effectiveness of the system of preventing and combating corruption;

7) informing about the policy of preventing and combating corruption both within the University and in relations with business partners, officials, public authorities, local governments, other legal entities and individuals;

8) providing, in accordance with the Law of Ukraine "On Prevention of Corruption", conditions for reporting information about possible facts of corruption or corruption-related offenses, other violations of the Law of Ukraine "On Prevention of Corruption";

9) observance of the rights and guarantees of protection of whistleblowers provided for by the Law of Ukraine "On Prevention of Corruption";

10) timely and proper response in accordance with the law to the facts of committing (possible commission) of corruption or corruption-related offenses by employees of the University and students.

4. Business hospitality policies and procedures. Gifts

4.1 The University, taking into account the requirements of the law, determines the general policy and procedures for providing and accepting business hospitality and gifts.

4.2. The Rector, officials of all levels, employees, representatives of the University are obliged to refrain from offering business hospitality, gifts to officials, their relatives, actual or potential business partners, their employees or representatives, if such business hospitality, gifts can be regarded as an inducement or readiness to commit a corruption offense related to the activities of the University.

4.3. Giving and receiving gifts, as well as providing and accepting business hospitality within the framework of establishing or maintaining business relations or to achieve another goal of the University is allowed if it meets a combination of the following criteria

1) it is not intended to influence the objectivity of any decision to make transactions, provide or receive services, information, or any other benefits for the University;

2) is not a hidden undue advantage (for example, assessment of knowledge; to obtain or continue to obtain commercial orders or an undue advantage);

3) is in line with generally accepted notions of hospitality (e.g., a gift is a souvenir);

4) not prohibited by the laws of the country in which they are provided and/or accepted;

5) the cost does not exceed the limits established by the legislation and the University;

6) not prohibited by the internal documents of the recipient's organization and does not exceed the value established by such documents;

7) disclosure of the gift, business hospitality will not create a risk to the business reputation of the University or the recipient of the gift, business hospitality;

8) gifts, business hospitality are reasonable, not excessive and appropriate in the context of establishing/maintaining business relations.

4.4. Giving and receiving gifts in the form of cash (cash or non-cash), cash equivalent (gift cards or gift vouchers) is not allowed.

4.5. In case of doubts about the acceptability of a gift or business hospitality, employees should contact the Commissioner in accordance with the procedure established by this Program for advice and/or clarification.

4.6. The Rector, vice-rectors and heads of structural subdivisions, officials of all levels, employees, representatives of the University shall notify the Commissioner within one working day of the facts of giving (making) or receiving a gift / business hospitality within the generally accepted concepts of hospitality in accordance with the procedure established by the University.

5. Charitable and sponsorship activities

The University, as a state institution maintained at the expense of budgetary funds, does not carry out charitable and sponsorship activities for the benefit of others.

6. Support of political parties

The University does not support political parties in accordance with the requirements of the Law of Ukraine "On Higher Education".

7.Inspection during mergers and acquisitions

The decision on organizational changes of the University (merger, division, acquisition, liquidation) is made by the central executive body in the field of education and science.

8. Vetting of candidates for positions

8.1. For the purpose of implementing this Program, the University, within the framework of personnel selection procedures, shall check candidates for positions vulnerable to corruption risks.

8.2. Candidates for positions are screened in order to:

1) to establish whether the conclusion of an employment contract with a candidate does not cause corruption risks for the University;

2) to establish whether the conclusion of an employment contract with a candidate will not lead to a violation of anti-corruption legislation;

3) make sure that the candidate undertakes to comply with the requirements of this Program.

8.3. The decision to conclude an employment agreement shall be made in compliance with the requirements of anti-corruption legislation.

8.4. Candidates for positions vulnerable to corruption risks shall be screened by the Commissioner. Based on the results of the inspection, the Commissioner prepares a reasoned conclusion for the Rector of the University on the presence or absence of corruption risks.

8.5. The procedure for screening candidates for positions and the list of positions vulnerable to corruption risks shall be determined by the University.

8.6. The materials of the verification of candidates for positions vulnerable to corruption risks shall be kept in personal files for the entire period of their storage.

VII. Notifications, their verification and responsibility

1. Notification of possible facts of corruption or corruption-related offenses, other violations of the Law of Ukraine "On Prevention of Corruption"

1.1. The University creates favorable conditions for whistleblowers and fosters respect for whistleblowers as part of the University's business culture.

1.2. The University provides whistleblowers with conditions for reporting possible facts of corruption or corruption-related offenses, other violations of the Law of Ukraine "On Prevention of Corruption" (hereinafter - the Report) by:

1) mandatory establishment and operation of channels through which a person can make a Report, while guaranteeing his/her anonymity (hereinafter referred to as the Reporting Channels), if necessary, through the Single Whistleblower Reporting Portal;

2) determining, in accordance with the Law of Ukraine "On Prevention of Corruption", internal procedures and mechanisms for accepting and reviewing Reports, verifying and responding to them appropriately;

3) providing methodological assistance and consultations to potential whistleblowers on how to make a report;

4) implementing mechanisms for encouraging and fostering a culture of reporting;

5) observing the rights and guarantees of whistleblower protection.

1.3. Whistleblowers independently determine which Reporting Channels to use to make a Report.

1.4. The Whistleblowers are guaranteed confidentiality in accordance with the procedure and under the conditions established by the Law of Ukraine "On Prevention of Corruption".

1.5. A person may make a Report without attribution (anonymously).

1.6. Information about the Reporting Channels is brought to the attention of all employees, including during recruitment, posted on the information stands of the University and on the University website (https://kpi.ua/anticor).

1.7. The University encourages business partners to report through the Reporting Channels any facts of corruption or corruption-related offenses, other violations of the Law of Ukraine "On Prevention of Corruption" by the Rector, Vice-Rectors and heads of structural units of all levels, employees and representatives of the University.

1.8. The notification shall contain factual data confirming the possible commission of a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption" that can be verified.

1.9. An anonymous Report shall be subject to consideration if the information provided therein relates to a specific person and contains factual data that can be verified.

1.10. Means of encouraging the Notification are realized by the University through:

1) approval of internal documents of the University, which determine the forms of incentives, organizational principles of the functioning of the incentive mechanism;

2) providing methodological assistance and advice on the implementation of the Notice;

3) moral and material encouragement of whistleblowers.

1.11. Means of forming a culture of reporting are realized by the University through:

1) approval of internal documents of the University on ethical behavior at the University, in particular, the formation of respect for whistleblowers as responsible citizens

2) conducting internal trainings on the formation of a culture of reporting;

3) systematic implementation of educational and communication activities.

2. Rights and guarantees of whistleblower protection

2.1. Whistleblowing is an honorable right of every employee of the University.

2.2 The whistleblower has the rights and guarantees of protection provided for in Articles 53-3 to 53-8 of the Law of Ukraine "On Prevention of Corruption", in particular:

1) to submit evidence to support his/her Report;

2) to receive confirmation of acceptance and registration of the Report

3) to confidentiality;

4) to receive information on the status and results of consideration, verification and/or investigation of the information on the fact of the information reported by him/her;

5) to be released from legal liability for making the Notification, disseminating the information specified in the Notification, despite the possible violation of their labor, civil or other duties or obligations by such Notification;

6) to be released from civil liability for property and/or moral damages caused as a result of the Communication, except in the case of a deliberately false communication.

2.3. The rights of a whistleblower arise from the moment of making a Notice containing factual data confirming the possible commission of a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption" that can be verified.

2.4. The whistleblower shall be provided with guarantees of protection of his/her rights in accordance with the procedure and under the conditions established by the Law of Ukraine "On Prevention of Corruption".

2.5. It is prohibited to disclose information about the identity of the whistleblower, his/her close relatives or other data that may identify the identity of the whistleblower, his/her close relatives to third parties who are not involved in the consideration, verification and/or investigation of the facts reported by the whistleblower, as well as to persons whose actions or inaction relate to the facts reported by the whistleblower, except in cases established by law.

2.6. Only the Rector of the University, the Authorized Representative and employees designated by him/her involved in the process of accepting and reviewing the Reports at the University have access to information about the whistleblowers.

2.7. In case of leakage of confidential information about the whistleblower, the Commissioner, the Rector of the University at the request of such person or on his/her own initiative shall immediately take all measures to avoid negative consequences for the whistleblower related to such disclosure.

2.8. The University prohibits intimidation, humiliation or harassment of whistleblowers, application of other negative measures of influence (refusal to hire; dismissal or coercion to dismiss; disciplinary action; other measures, including formally legitimate decisions and actions that are selective, in particular, not applied to other employees in similar situations and/or not applied to the employee in similar situations before) or threats of such measures of influence.

2.9. A Whistleblower may not be dismissed or forced to resign, disciplined, or subjected to other negative measures of influence or threat of such measures of influence in connection with the Report.

2.10. The Rector of the University, vice-rectors and heads of structural units of all other levels, the Commissioner within their powers shall provide conditions for the protection of whistleblowers.

2.11. The rights and guarantees of protection of whistleblowers shall be extended to close persons of the whistleblower.

3. Reporting possible facts of violations of this Program

3.1. Employees and persons studying at the University or performing certain work, representatives, as well as business partners of the University may report the detected signs of violations of this Program, facts of incitement of employees, managers, officials of all levels of the University to commit corruption or corruption-related violations, other violations of the Law of Ukraine "On Prevention of Corruption" directly to the Rector of the University, the Commissioner by sending an e-mail to anticor@kpi.ua or to the Rector of the University. The University may provide for other ways of transmitting and receiving information.

3.2. The procedure for consideration of such notifications, interaction with the applicant, guarantees of confidentiality of information about the applicant and protection of his/her rights are determined by an internal document of the University.

4. Conducting internal investigations

4.1 In case of receipt of the Notice or detection of signs of committing

of a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption" or this Program by the Vice-Rector and/or head of a structural unit, employee or representative of the University, the Commissioner shall conduct a preliminary examination of the information received (revealed) in accordance with the requirements of the Law of Ukraine "On Prevention of Corruption" and internal documents of the University.

4.2. If the received (detected) information about the commission of a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption" concerns the actions or inaction of the Rector of the University, the Commissioner shall send such information without preliminary verification to the entity authorized to review or investigate it within three days, taking into account the jurisdiction defined in Article 216 of the Criminal Procedure Code of Ukraine and the provisions provided for in Article 255 of the Code of Ukraine on Administrative Offenses.

The received (discovered) information shall also be sent to the entity authorized to appoint (elect) and dismiss the Rector of the University.

4.3. In case of receipt of a Notice or detection of signs of a corruption or corruption-related offense by the Commissioner, other violation of the Law of Ukraine "On Prevention of Corruption" or this Program, a preliminary verification of such information is carried out in accordance with the internal documents of the University.

4.4. Based on the results of the preliminary inspection, the following decision(s) shall be made:

1) take measures to stop the identified violation;

2) to appoint an internal investigation in case of confirmation of the facts stated in the Notice (revealed) or the need for further clarification of their reliability;

3) in case of detection of signs of a corruption or corruption-related offense, immediately, within 24 hours, notify in writing the specially authorized entity in the field of combating corruption of its commission;

4) close the proceedings in case of failure to confirm the facts stated in the Notification (revealed).

4.5. The purpose of the internal investigation is to verify the factual data on possible commission of a corruption or corruption-related offense, other violation of the Law of Ukraine "On Prevention of Corruption" or this Program.

4.6. The internal investigation shall be conducted by the commission.

4.7. The Commissioner shall be a member of the commission, unless the investigation is appointed as a result of the discovery of facts or receipt of information about the commission of a corruption or corruption-related offense by the Commissioner, or other violation of the Law of Ukraine "On Prevention of Corruption" or this Program.

4.8. All officials and employees of the University, regardless of their position, are obliged to facilitate the internal investigation and provide the necessary available documents and materials.

4.9. An official or employee of the University in respect of whom an internal investigation is being conducted may be temporarily suspended from work (if there are grounds provided for by law) or otherwise restricted in access to material, information and other resources of the University during the internal investigation on the basis of a decision of the Rector of the University or, if the investigation concerns the Rector of the University, on the basis of a decision of the body whose powers include the appointment (election) and dismissal of the Rector of the University.

4.10. Based on the results of the internal investigation, the following decision(s) shall be made:

1) to take measures to stop the revealed violation;

2) to apply disciplinary sanctions to the guilty persons;

3) to determine ways to eliminate the causes and conditions of the violation and the consequences caused by it, to take measures to prevent such violations in the future;

4) take measures to restore the rights and legitimate interests of individuals and compensate for losses and damage caused to individuals and legal entities as a result of the violations;

5) transfer the materials to the pre-trial investigation body in case of establishing signs of a criminal offense or to other bodies authorized to respond to the detected offenses.

4.11. The term for conducting an internal investigation shall not exceed thirty (30) calendar days from the date of completion of the preliminary inspection. If it is impossible to verify the reported (revealed) information within the specified period, the Rector of the University extends the term of the internal investigation up to 45 days.

4.12. The procedure for conducting internal investigations is determined by the University.

4.13. The Commissioner has access to the materials of internal investigations, which are stored for at least 5 years.

5. Disciplinary responsibility for violation of this Program

5.1. For violation of the provisions of this Program, the University employees are subject to disciplinary measures in accordance with the law, the internal regulations of the University, and the provisions of employment contracts.

5.2. The Human Resources Department of the University sends to the National Agency for the Prevention of Corruption a certified paper copy of the decision (order) of the Rector of the University on the imposition of a disciplinary penalty and an information card to the administrative document on the imposition (cancellation of the administrative document on the imposition) of a disciplinary penalty on a person for committing corruption or corruption-related offenses in order to enter information on the imposition of a disciplinary penalty for committing a corruption or corruption-related offense.

5.3. The Rector of the University ensures that measures are taken for committing a corruption or corruption-related offense.

VIII. Supervision, control, amendments to this Program

1. Supervision and control

1.1. The Commissioner supervises and constantly monitors compliance with this Program by the Rector of the University, vice-rectors and heads of structural units of all levels, employees and representatives of the University and students.

1.2. The Commissioner shall supervise and control compliance with this Program by:

1) reviewing and responding to Notifications;

2) conducting inspections of the activities of the University employees regarding the implementation of this Program;

3) conducting inspections of organizational and administrative documents, transactions, other documents of the University, the University provided for in this Program, as well as their projects for corruption risks;

4) periodic monitoring of the implementation of this Program.

1.3. The University may determine the procedure for conducting scheduled and unscheduled inspections of the activities of University employees, the procedure for conducting document reviews, as well as additional forms of supervision and control over compliance with this Program, taking into account the specifics of its activities.

1.4. If during the supervision or control of compliance with this Program the Commissioner finds signs of a corruption or corruption-related offense, the Commissioner initiates an internal investigation before the Rector of the University in the manner prescribed by this Program and internal documents of the University.

1.5. The Authorized Department at least once every 6 months within the terms and in the manner determined by the Rector of the University prepares a report on the results of monitoring the implementation of this Program (hereinafter - the Report). Such a report shall be equivalent to an annual assessment of the results of the implementation of measures provided for in this Program.

If there are Responsible Persons in separate subdivisions of the University to whom the powers of the Commissioner for Anti-Corruption Activities are delegated, the Responsible Persons shall ensure the preparation of a consolidated Report.

1.6. The report shall include information on:

1) the status of implementation of the measures defined in this Program;

2) the results of implementation of the measures defined by this Program;

3) identified violations of the Law of Ukraine "On Prevention of Corruption", this Program, measures taken to eliminate such violations and prevent their future occurrence;

4) the number of inspections and internal investigations conducted and their results;

5) facts of violation of guarantees of the Commissioner's independence;

6) the status of implementation of measures aimed at eliminating or minimizing corruption risks;

7) training activities on prevention and detection of corruption and the state of assimilation of the knowledge gained;

8) cooperation with whistleblowers;

9) newly identified corruption risks;

10) proposals and recommendations.

1.7. The report may contain other information related to the implementation of this Program.

1.8. The generalized results of monitoring the implementation of this Program are placed in the general public domain for employees of the University, as well as on the official website of the University.

1.9. The Commissioner ensures at least once a year to organize the evaluation of the results of the implementation of measures provided by this Program.

1.10. The results of the evaluation shall be summarized by the Commissioner in a written report, which he/she shall submit to the Rector of the University, the Supervisory Board and the founders of the University.  

1.11. Evaluation of the results of the implementation of measures provided for in this Program is carried out according to the criteria determined by the Commissioner and must contain information in the amount not less than that provided for in the Report.

2.Amendments to this Program

2.1. The Rector of the University ensures the organization of feedback mechanisms and other internal processes aimed at maintaining and continuously improving this Program.

2.2 This Program is reviewed in the following cases:

1) based on the results:

- assessment of corruption risks in the University's activities;

- supervision and control over compliance with this Program, as well as evaluation of the results of the implementation of the measures provided for by it;

2) in case of amendments to the legislation, including anti-corruption legislation, that affect the activities of the University;

3) in case of changes in the organizational structure and business processes of the University (if necessary).

2.3 The Commissioner may initiate changes to this Program, as well as the Rector of the University, the Supervisory Board, officials of all levels, and employees of the University.

2.4. Proposals for amendments to this Program shall be submitted to the Commissioner, who shall study and systematize them.

2.5. Once a year, the Commissioner provides the Rector of the University with a summary of proposals for amendments to this Program and provides his/her recommendations for their consideration or rejection.

2.6. The Rector of the University, having received from the Commissioner a summary of proposals for amendments to this Program, initiates an open discussion by employees (labor collective).

2.7. In cases where the Commissioner insists on urgent introduction of certain changes to this Program, the Rector of the University shall initiate a relevant discussion as soon as possible, but not later than 10 days from the date of receipt of such proposals.

2.8. In case of approval of proposals for amendments to this Program by employees (staff) of the University, the Rector of the University by his decision (order) approves the relevant changes, which are an integral part of this Program.

2.9. Amendments to this Program may not establish standards and requirements lower than those provided by the Law of Ukraine "On Prevention of Corruption" and the Model Anti-Corruption Program of a legal entity approved by order of the National Agency for the Prevention of Corruption.