Anti-corruption program of the National Technical University of Ukraine "Kyiv Polytechnic Institute"

The project of Anti-Corruption program of the National Technical University of Ukraine "Kyiv Polytechnic Institute" was considered at the meeting of a labour collective on 04/09/2015.

Approved by the Academic Council Minutes № 4 from 05.12.2015.

1. GENERAL PROVISIONS
2. TERMS USED IN ANTI-CORRUPTION PROGRAMS
3. THE PURPOSE OF ANTI-CORRUPTION PROGRAMS
4. THE PRINCIPLE OF ANTI-CORRUPTION PROGRAMS
5. ANTI-CORRUPTION MEASURES, CONDUCTING IN THE UNIVERSITY DURING IMPLEMENTATION OF THE ECONOMICAL ACTIVITY
6. NORMS OF PROFESSIONAL ETHICS OF THE UNIVERSITY
7. DUTIES OF EMPLOYEES OF UNIVERSITY DUE TO THEPREVENTION AND COUNTERACTION OF CORRUPTION IN ACTIVITY OF UNIVERSITY.
8. LEGAL STATUS, RIGHTS AND REPRESENTATIVE'S DUTIES
9. THE ORDER OF THE REGULAR REPORTING OF THE UNIVERSITY AUTHORIZED BEFORE THE RECTOR
10. MONITORING AND CONTROL OF OBSERVANCE OF THE ANTI-CORRUPTION PROGRAM
11. CONFIDENTIALITY OF PROFESSIONALS BY THE AUTHORIZED WORKER ABOUT THE FACTS WHICH ARE PICKED UP THEM TO COMMISSION OF A CORRUPTION OFFENSE OF ILI O MADE BY OTHER WORKERS OR PERSONS CORRUPTION OR IT IS CONNECTED WITH CORRUPTION OF OFFENSES. PROTECTION OF THE WORKERS GIVING HELP IN PREVENTION AND COUNTERACTION OF CORRUPTION
12. INFORMING THE REPRESENTATIVE FROM UNIVERSITY ABOUT EMERGENCE REAL, POTENTIAL THE CONFLICT OF INTERESTS, AN ORDER OF SETTLEMENT OF THE INTERESTS REVEALED THE CONFLICT
13. CARRYING OUT INDIVIDUAL CONSULTATION BY THE AUTHORIZED EMPLOYEE OF UNIVERSITY CONCERNING ANTI-CORRUPTION STANDARDS AND PROCEDURES OF CARRYING OUT INCREASE OF THEIR QUALIFICATION IN THE SPHERE OF THE PREVENTION AND COUNTERACTION OF CORRUPTION
14. AN ORDER OF CARRYING OUT PERIODIC PROFESSIONAL DEVELOPMENT OF EMPLOYEES OF UNIVERSITY IN THE SPHERE OF THE PREVENTION AND COUNTERACTION OF CORRUPTION
15. TAKING MEASURES OF REACTION TO THE ELICITED FACTS OF THE CORRUPTION OR CONNECTED WITH CORRUPTION OFFENSES AT UNIVERSITY
16. A MODIFICATION ORDER IN THE ANTI-CORRUPTION PROGRAM

1. GENERAL PROVISIONS

This program is designed in accordance with the Constitution of Ukraine, the Law of Ukraine «Prevention of Corruption" (hereinafter - the Law), the Law of Ukraine "Principles of anti-corruption policy in Ukraine (Anti-corruption Strategy) during 2014-2017 years" and other anti-corruption legislation of Ukraine.

Anticorruption program applies to all employees of the National Technical University of Ukraine "Kyiv Polytechnic Institute" (hereinafter - the University), including persons who do practical\educational training or work under contract that may be equated to employment contracts.

Anti-corruption measures aimed at:

• Prevention of corruption, including identifying and eliminating the causes of corruption (corruption prevention);
• Identification of corruption offenses, detection and investigation of corruption offenses;
• Minimization and mitigation of corruption.

2. Terms used in anti-corruption programs

Anti-corruption expertise - activities of detection in statutory instrumentsor in the projects of statutory instruments  the statutes that on a standalone basis or in combination with other standards can contribute to corruption offenses or offenses related to corruption;

Direct subordination - the relationship of direct organizational or legal dependence subordinate entity on its leader, including solving (participation in solving) questions of recruitment, dismissal, the use of incentives, disciplinary measures, providing guidance, instructions, etc., monitoring their implementation;

Close persons - persons who live together, connected by common life and have mutual rights and obligations with subject specified in paragraph 1 of Article 3 of the Act (except natural entities whose rights and obligations with the subject haven’t family character), including persons who live together but are not married, and - regardless of the specified conditions - husband, wife, father, mother, stepfather, stepmother, son, daughter, stepson, stepdaughter, brother , sister, grandfather, grandmother, grandfather, great-grandmother, grandson, granddaughter, grandson, granddaughter, son, daughter, father, mother-, father in law, mother in law, adoptive parent or adopted child, guardian or caregiver, the person under guardianship or trusteeship mentioned subject;

Corruption offense - an act that has signs of corruption committed by a person in referred to the part of the first Article of third Act, for which the law provides criminal, disciplinary and  or civil liability;

Corruption - the use by the person referred to  the part of the first Article of third Act official powers or associated with them  possibilities to obtain undue advantage or acceptance of such interests or adoption promise / offer of such interests for themselves or othersPromise / offer or giving improper advantage to a person referred in paragraph 1 of Article 3 of the Act.

Giving improper advantage on request to another natural or legal person with the purpose to persuade that person to the unlawful use of granted power or  related to them opportunities;

Illegal benefit - cash or other assets, advantages, benefits, services, intangible assets, and any other immaterial benefits  that are promised, offered, given or received without legal justification;

Potential conflict of interest - a person having a private interest in the field in which it performs its official powers or representation, which may influence on objectivity or impartiality of its decisions, or on commitment or omittance actions at the time of the execution of these powers;

Gift - cash or other assets, advantages, benefits, services, intangibles that give / get for free or at a price below the minimum market;

Offenses related to corruption - an act that does not contain evidence of corruption, but violate legal requirements, prohibitions and restrictions committed by a person referred to in paragraph 1 of Article 3 of the Act, for which the law provides criminal, administrative, disciplinary and / or civil and legal  responsibility;

private interests - any property or non property interest of entity, including interest aroused due to personal, family, or other out-of-office  relationship with natural or legal persons, including those arising from membership or activity in the public, political religious or other organizations;

real conflict of interests - conflict between private interest of entity and its official or representative powers that affect the objectivity or impartiality of making decisions or influence on commitment or omittance  actions  during the execution of these powers;

declaring subjects - the persons referred to  paragraph 1, sub-paragraph "a" of paragraph 2 of the first part of the law, other persons who are required to submit a declaration under the Law;

Family members - persons who are married, and their children, including adults, parents, persons under guardianship, and other persons who live together or related by joint household, mutual rights and responsibilities (except those reciprocal rights and obligations which haven’t family character), including persons who live together but are not married.

3. The purpose of anti-corruption programs

Anticorruption Program of the University reflects the support of the anti-corruption strategy of the state, as evidenced by the use of ethical standards and principles providing information on works and services, the set prices, reflecting the desire of the university to improve the corporate culture, inheritance of best corporate governance practices, maintaining business reputation of the University for mark.

University defines the following aims:

• minimization of risks of involving direction and staff of the University in a corrupt activity, regardless of position;
• form awareness and understanding of a single anti-corruption program of the University, the rejection of corruption in all its expressionamong counterparties, employees and other persons;
• summarize and explain the main provisions of anti-corruption legislation of Ukraine;
• include knowledge and respect for the principles and requirements of the anti-corruption program, the main provisions of anti-corruption legislation and taking appropriate measures to prevent corruption  to the duty of University staff .

4. The principle of anti-corruption programs

Rector of the University and heads of departments form ethical standards of negative attitude to any manifestations of corruption, setting an example for their own behavior and making acquaintance with anti-corruption laws of all employees and contractors.

Rector of the University is responsible for organizing activities aimed at implementation of the principles and requirements of anti-corruption programs, including the appointment of the persons responsible for the development of anti-corruption measures and monitoring their implementation.

All employees of the University should be guided by the current legislation and the anti-corruption program, observe the principles and requirements of this program.

The principles and requirements of anti-corruption program apply to contractors and representatives of the University, and also to others entities when relevant obligations enshrined in the treaties in their internal documents, or directly provided by law.

Creation of a system of anti-corruption measures based on the following key principles:

• In accordance with work of the University to current legislation and generally accepted standards;
• in accordance with  anti-corruption measures implemented in the University , with the Constitution of Ukraine, laws of Ukraine and other normative legal acts, which are used at the University;
• Personal example of leadership. A key role of the leadership of the University is creating a culture of zero tolerance for corruption and the creation of in-house system of preventing and combating corruption;
• involving employees of the University to eradicate corruption, in particular, the awareness of employees of the University of the provisions of anti-corruption legislation and their active participation in the formulation and implementation of anti-corruption standards and procedures;
• proportionality of anti-corruption procedures of corruption risk;
• effectiveness of anti-corruption procedures - using in University  anticorruption measures that have low economic efficiency, ensure ease of implementation and bring significant results;
• responsibility and punishment inevitability - the inevitability of punishment regardless of the position, length of service and other conditions in the case of employee corruption offenses related to performance of duties;
• continuous monitoring and regular monitoring.

5. ANTI-CORRUPTION MEASURES, CONDUCTING IN THE UNIVERSITY DURING IMPLEMENTATION OF THE ECONOMICAL ACTIVITY

The person responsible for implementing anti-corruption programs (hereinafter – the authorized person) corresponding to the anti-corruption program of the University developed a specific list and description of anti-corruption measures to be implemented to prevent and combat corruption in the University.

To identify the risks that may face the University due to violation of anti-corruption legislation, university authorities should periodically conduct internal audits of its business units.

The audit findings can reveal high-risk areas and develop an effective plan of action aimed at neutralizing the legal and commercial risks of University.

Risk assessment - a continuous process of constant communication between the rector, the Commissioner and staff of the University.

When working with contractors a risk assessment should be carried out.

 Use of intermediaries, partners, agents, joint ventures or other persons in order to commit any acts contrary to the principles and requirements of anti-corruption programs or standards of anti-corruption legislation is forbidden for the direction of the University and its employees.

University selects contractors to give them work and services based on the principle of selection of contractor at the best competitive prices, which provides:

• Analysis of the market of services;
• Equality, justice, non-discrimination and unjustified restrictions on competition in relation to the counterparty;
• Honest and reasonable choice of offers during integrated analysis of benefits and costs (particularly for prices and quality of products);
• intended and cost-effective expenditure of funds for the purchasing of goods, works and services (including, if appropriate, life-cycle cost of purchasedproduction) and implementing measures to reduce costs of the University;
• Lack of access restrictions to participation in the procurement by setting undue requirements for counterparty (excessive requirements for counterparty are not considered those requirements that expressly provided by the current legislation on the implementation of public procurement, etc.);
• prevent corrupt acts, conflicts of interest and other abuse of authority.

The University aims to have business relationships with contractors that support the requirements of anti-corruption legislation and / or contractors that declare rejection of corruption.

The University claims  about refusing of stimulation of contractorsworkers in any way, including by providing cash, gifts, free service supply and others ways,that puts the contractor worker in a dependency and directed to enforcement  of any action in favor of the University by the employee.

The University applies efforts in order to minimize the risk of business relations with contractors who may be involved in corrupt activities, for which the tolerance control to corruption of contractors is conducted , including the  control of existence  of their own anti-corruption programs, their willingness to comply with this anti-corruption program and includes in treaties anti-corruption  conditions (warnings), and provides mutual assistance for ethic business conduction  and prevention of corruption.

In case of violation of anti-corruption legislation, University and it’s contractors (partners) must:

• immediately notify each other in writing about any violations of anti-corruption legislation;
• During the implementation (execution) of any transactions (contracts) remind others about the obligation to adhere to anti-corruption legislation.

In the case of appearance of objective facts indicating a violation of anti-corruption legislation  by contractors at the University, a message with a demand of providing appropriate explanations is sent on the address of the contractor (partner).

Failure to submit sufficient evidence that definitely confirm the absence of violations of anti-corruption legislation is a violation of the essential conditions of the contract (fundamental breach) concluded between the University and its contractor and empower the University to terminate a contract unilaterally out of court (completely abandon the contract) or pause further implementation unilaterally in some part of it (partly abandon the contract) by sending a written message.

Regulatory support, consolidation of standards of conduction and declaration of intents by University provides:

• The development and adoption of a code of ethics and official conduction of the University emploees;
• Development and adoption of regulations on conflict of interest;
• Include in contracts related to the business activities of the University, a conventional anti-corruption message - warning of violations of anti-corruption legislation.

Development and introduction of special anti-corruption procedures provides:

• Introduction of procedure of informing the employer by employees about the cases of provocation them to corruption offenses commitment;
• The introduction of procedureof informing the University about cases of corruption offenses commited by other employees, contractors University or others that have become known to the employee.

University provides training and information to staff on compliance with anti-corruption legislation, namely:

• familiarization  workers with the regulations governing the prevention and combating corruption at the university;
• arranging training activities on prevention and combating corruption;
• organization of individual counselingfor staff on application (compliance)of  anti-corruption standards and procedures.

Compliance of the system of internal control requirements at the University with anticorruption policy is provided by the control of accounting, the availability and reliability of primary accounting documents. All financial transactions carried out at the University should be carefully, correctly and with a sufficient level of detail reflected in accounting ,documented and be available for inspection.

Distortion or falsification of financial statements of the University are strictly prohibited and regarded as an offense.

All employees of the University are strictly forbidden directly or indirectly, personally or through third partie,  to engage in corrupt practices, offer, give, promise, request or receive bribes or payments to simplify administrative, bureaucratic and other formalities in any form, including those in the form of cash, property, services or other benefits to any person and from any persons or organizations, including commercial organizations and government authorities, civil servants, private companies and their representatives.

Employees of the University are forbidden directly or through others entities to require, request, receive gifts for themselves or persons close to them from legal entities and individuals:

• in connection with such persons activities related to the performance of their duties at the University;
• If the person who gives, is subordinate to that person.

University employees can accept gifts that fit generally accepted notions of hospitality, in cases where the value of such gifts do not exceed one minimum wage established on the date of gift, single time, and the total value of gifts received from one source during the year does not exceed two  subsistence minimum for able-bodied person on 1 January this year.

Limitations on the value of gifts does not apply to gifts that are:

• made by close persons;
• received as generally accessible discounts on goods, services, public winnings, prizes, awards, bonuses.

In the case of a taking a decision by University employee in favor of the entity from whom he or his close people have received a present, decisions of this worker are deemed adopted in conflict of interest.

In the case of a proposal of undue benefit or gift, employees of the University regardless of private interests, must immediately take the following measures:

• abandon the proposal;
• if the capacity will be available  identify the person who made the offer;
• involve witnesses, if possible, including the number of employees;
• notify supervisor or the Commissioner, specifically authorized entities in combating corruption about the proposal.

If the person  covered by the restrictions on receiving gifts, revealed in its official premises or received  property, which may be unlawful benefit or gift, it must immediately, but not later than one working day notify about that fact its supervisor or the Commissioner in written form.

On detection of property that may be unlawful benefit or present is made an act that should be  signed by the person who found the undue benefit or gift, and her immediate supervisor or the Commissioner.

If the property that may be unlawful benefit or gift is revealed by Rector, Head of the University, the act of identifying assets that may be unlawful benefit or gift to the person is signed by this entity  and the Commissioner.

The objects of undue benefits and gifts received or found are stored at the University before its transferring to a specially authorized entities in combating corruption.

In case when a University employee has doubts about the possibility of receiving the gift , he has the right to appeal to the Commissioner or territorial authority National Agency which provides the appropriate explanation in writing in order to obtain advice on this matter.

Cooperation with civil servants.

Direction of the University does not pay any costs (monetary rewards, loans, services, payment for entertainment, recreation, transportation costs and other fees) for civil servants and their close relatives (or their interests) on a stand-alone basis or through it’s employees in order to obtain or saving benefits to the University in business.

Employees of the University are responsible for the corruption on a stand-alone basis in the case of independent interactions with government officials according to the current legislation of Ukraine.

6. NORMS OF PROFESSIONAL ETHICS OF THE UNIVERSITY

During performing official duties University workers should strictly observe the requirements of law and generally accepted ethical standards, be courteous in relations with citizens, supervisors, colleagues and subordinates.

During the performance of the official duties employees of NTU "KPI" are required

• observe political neutrality and avoid demonstration of their political beliefs or views in any way, do not use official authority in the interests of political parties or their cells or individual politicians; 
• not to disclose and not to use otherwise confidential and other information with limited access which became known for it in connection with performance of the office powers and professional duties, except the cases established by the law;
• to affect impartially, despite private interests, the personal attitude towards any persons, the political views, ideological, religious or other private judgments or belief;
•  honestly, competently, in due time, productively and responsibly to carry out professional duties, decisions and orders and persons to whom they are subordinated, accountable or under control, don't allow abuses and inefficient use of state ownership;
• to abstain from implementation of decisions or instructions of the management if they contradict the law, despite private interests.

In case of receiving for implementation of decisions or instructions which the person, considers illegal or posing threat to the rights protected by the law, freedoms or interests of certain citizens, legal entities, the state or public interests, she has to report immediately in writing about it the rector of University.

7. DUTIES OF EMPLOYEES OF UNIVERSITY DUE TO THEPREVENTION AND COUNTERACTION OF CORRUPTION IN ACTIVITY OF UNIVERSITY

The following duties connected with prevention and counteraction of corruption are assigned to employees of University:

• to abstain from commission and (or) participation in commission of corruption offenses in interests or on behalf of University;
• to abstain from behavior which can be interpreted by people around as readiness to make or participate in commission of a corruption offense in interests or on behalf of University;
• immediately to inform the direct head, the Representative or the management of University on existence cases at the worker of intention to make a corruption offense;
•  immediately to inform the direct head, the Representative or the management of University on cases of accountability for commission of a corruption offense;
•  immediately to inform the direct head, the Representative or the management of University about the famous worker information on cases of commission of corruption offenses by other workers, contractors of University or other persons;
• to report to the direct head or the Representative about emergence or possibility at the worker of the conflict of interests.

It is forbidden to employees of University:

• to use the powers or the situation and opportunities connected with it for the purpose of obtaining illegal benefit for itself or other persons, including to use any property of University or means in private interests;
• directly or through other persons to demand, ask, receive gifts for itself or close persons from legal or natural persons in connection with performance of the powers assigned to such faces and also if the person who gives, is under supervision of such person.
• directly or indirectly to induce in any way of subordinates to decision-making, commission of actions or inaction contrary to the law in favor of the private interests or private interests of the third parties.

8. LEGAL STATUS, RIGHTS AND REPRESENTATIVE'S DUTIES

Legal status of the Representative

The representative is the official of University, the rector of University appointed according to the legislation on work by the order.

The natural person who is capable on the business and moral qualities, professional level can be authorized, for health reasons to carry out the corresponding duties.

The person, which can't be appointed to the Representative's position:

• has the outstanding or not removed in the order established by the law criminal record;
•  it is by a court decision recognized incapacitated or which capacity is limited;
• it is dismissed in government bodies, authorities of the Autonomous Republic of Crimea, local governments for violation of the oath or in connection with commission of the corruption offense or offense connected with corruption - within three years from the date of such release.

Work in the positions specified in point of 1 part one of article 3 of the present Law, and also any other activity which creates the real or potential conflict of interests to activity of the legal entity is incompatible with activity of the Representative.

In case of circumstances of incompatibility the Representative in two-day time from the date of emergence of such circumstances is obliged to report about it the rector of University with simultaneous submission of the declaration of avoidance of the employment contract on own initiative.

The representative can be dismissed ahead of schedule in a case:

• cancellation of the employment contract at the initiative of the Representative;
• cancellation of the employment contract at the initiative of the rector of University on condition of providing consent by National agency;
• impossibility to carry out the powers for health reasons according to the conclusion of medical commission which is created according to the decision of specially authorized central executive authority realizing a state policy in health sector;
• introductions in validity of a judgment about recognition its incapacitated or it is limited capable, recognition it is unknown absent or announcements his dead;
• introductions in validity of a conviction of court concerning it;
• death.

The rector in writing reports National agency within two working days about release of the person from the Representative's position and provides urgent representation of the new candidate for the specified position.

Rights and Representative's duties

The representative when performing of the tasks assigned to it has the following rights and duties:

• to receive information from natural and legal entities on violation of requirements of the current legislation in the sphere of fight against corruption, to carry out an inspection of the possible facts of violation of the specified requirements at the request of the rector of University;
• to carry out at the request of the rector of University an inspection of the organization of work on the prevention and identification of corruption in divisions of University;
• to exercise monitoring and control over the implementation of acts of the legislation concerning ethical behavior, prevention and a settlement of conflicting interests in activity of employees of University;
• to receive from employees of University written explanations concerning circumstances which can testify to violation of the rules of ethical behavior, prevention and a settlement of conflicting interests, other requirements and restrictions provided by the current legislation and the anti-corruption program;
• to initiate carrying out office investigation, to take measures for accountability of the persons guilty of commission of the corruption or connected with corruption offenses;
• once a year to prepare and provide to the rector of University the report on realization of bases of the anti-corruption program;
• to carry out cooperation with persons, honestly report about the possible facts of the corruption or connected with corruption offenses;
• to make explanations, the methodical and consulting help with questions of ethical behavior, prevention and a settlement of conflicting interests, the prevention and identification of corruption in divisions of University and at contractors of University.
• to receive from employees of University written and oral explanations on the questions concerning performance of the functions and tasks assigned to it (including during the previous research of the facts which can testify to violation of the anti-corruption legislation.

In case of identification of signs of the corruption or connected with corruption offense or obtaining the message on corruption violation, the Representative initiates carrying out office investigation.

The materials Representative received during the investigation reports on the rector of University who takes measures for involvement of perpetrators to a disciplinary responsibility, and in case of detection of signs of a criminal or administrative offense also informs specially authorized subjects in the sphere of counteraction of corruption.

9. THE ORDER OF THE REGULAR REPORTING OF THE UNIVERSITY AUTHORIZED BEFORE THE RECTOR

The report on results of work on prevention and counteraction of corruption at University moves to the rector of University annually till December 20, and also on request of the rector of University - within a year in the time established to them.

10. MONITORING AND CONTROL OF OBSERVANCE OF THE ANTI-CORRUPTION PROGRAM

Due to the possible change in time of the corruption risks and other factors influencing activity of University, the National agency concerning prevention of corruption carries out monitoring of the introduced adequate measures for prevention of corruption, controls their observance, and in case of need reconsiders and improves them.

The university provides taking measures, necessary and proved for prevention and counteraction of corruption in activity to Uniyeversitet.

Development of such measures and control of their performance is provided by the Representative taking into account requirements of this Anti-corruption program.

The analysis of observance by employees of University of requirements of the anti-corruption legislation, this Anti-corruption program or other documents of University concerning prevention of corruption is carried out by the Representative.

By results of the carried-out analysis of preliminary data on participation of employees of University in violations of the law the Representative informs the rector of University by submission of the service record on confirmation. Thus if necessary by the Representative need of application of other control methods (carrying out check of activity of division, office investigation, etc.) can be initiated.

The representative informs the rector of University on results of the carried-out analysis.

Research of separate fields of activity of University is carried out by the Representative for the purpose of improvement of the operating processes for minimization of the available corruption risks on the principles determined by this Anti-corruption program.

An anti-corruption inspection can be carried out by the Representative on own initiative or at the request of the rector of University.

11. CONFIDENTIALITY OF PROFESSIONALS BY THE AUTHORIZED WORKER ABOUT THE FACTS WHICH ARE PICKED UP THEM TO COMMISSION OF A CORRUPTION OFFENSE OF ILI O MADE BY OTHER WORKERS OR PERSONS CORRUPTION OR IT IS CONNECTED WITH CORRUPTION OF OFFENSES. PROTECTION OF THE WORKERS GIVING HELP IN PREVENTION AND COUNTERACTION OF CORRUPTION

The university demands from the workers of observance of this anti-corruption program, informing them on the key principles, requirements and sanctions for violations.

At University safe, confidential and available ways of informing the rector of University, the Representative (the written statement addressed to the rector or the representative or the personal address, the notification by means of telephone or fax, e-mail, etc.) about the bribery facts will be organized from the persons providing services in interests of the commercial organization or from her name. To the rector of University or the Representative suggestions for improvement of anti-corruption actions and control, and also inquiries can arrive from workers and the third parties.

At University training concerning the conscientious message on the corruption facts, in particular is constantly provided:

• regular carrying out the information campaigns directed on formation of a mental set at workers on corruption rejection as way of a solution;
• increase of level of legal consciousness of workers, in particular, regarding awareness on the rights and freedoms, the mechanism of their realization, confidentiality and legal ways of protection of exposers;
• an explanation of the most important anti-corruption actions which are carried out in the state, provisions of the legislation on prevention of corruption, in particular, regarding definition of types and forms of corruption behavior;
• system carrying out educational actions for behavior model in these or those situations with possible corruption risks.

At University confidentiality conditions take root, namely:

• information about the exposer (the person, gives help in the prevention and counteraction of corruption) can be divulged only from its consent, except the cases established by the law;
• the message on violation of requirements of the Law can be carried out by the employee of University without indication of authorship (anonymously)
• all data about exposers and corruption manifestations of workers received from employees of University or other persons admit confidential;
• consideration of messages on corruption manifestations of workers is carried out taking into account provisions of Art. 53 of the Law;
• the anonymous message on violation of requirements of the Law is subject to consideration if information provided in it concerns the particular person, contains actual data which can be checked;
• the anonymous message on violation of requirements of the Law is subject to check no more than fifteen days from the date of its receiving in time. If in the specified time to check information containing in the message it is impossible, the rector of University prolongs the term of consideration of the message about thirty days from the date of its receiving.

Persons who give help in prevention and counteraction of corruption, are under protection of the state.

In the presence of threat of life, to housing, health and property of the persons giving help in the prevention and counteraction of corruption, or their close faces in connection with carried out to the message on violation of requirements of the Law and this anti-corruption program, law enforcement agencies can be applied to them legal, organizational and technical and others are directed on protection against illegal encroachments of a measure, provided by the Law of Ukraine "About safety of the persons participating in criminal legal proceedings".

The person or the member of his family can't be released or forced to release, is brought to a disciplinary responsibility or is subject from the rector of University to negative measures of influence (transfer, certification, change of working conditions, refusal in appointment to the highest position, reduction of a salary, etc.) or threat of such measures of influence in connection with the message it about violation of requirements of the Law and this anti-corruption program by other person.

In case of confirmation stated in reporting of information on violation of requirements of the Law and this anti-corruption program the rector of University takes measures for the termination the revealed violations, elimination of its consequences and involvement of perpetrators to a disciplinary responsibility, and in case of detection of signs of a criminal or administrative offense also informs specially authorized subjects' objects in the sphere of counteraction of corruption.

12. INFORMING THE REPRESENTATIVE FROM UNIVERSITY ABOUT EMERGENCE REAL, POTENTIAL THE CONFLICT OF INTERESTS, AN ORDER OF SETTLEMENT OF THE INTERESTS REVEALED THE CONFLICT

Employees of University are obliged:

• to take measures for prevention of emergence of the real, potential conflict of interests;
• to report no later than the next working day since the moment when learned or had to learn about existence from them the real or potential conflict of interests of the direct head;
• not to make actions and not to make decisions in the conditions of the real conflict of interest
• to take measures for settlement of the real or potential conflict of interests.

External a settlement of conflicting interests it is carried out in the way:

• elimination of the person from performance of a task, commission of actions, decision-making or participations in its acceptance in the conditions of the real or potential conflict of interests;
• application of external control of execution by the person of the corresponding task, commission by it of certain actions or decision-making;
• restriction of access for the person to certain information;
• viewing of volume of office powers of the person;
• transfer of the person to other position;
• release of the person.

The head of the structural unit in whom the person having the conflict of interests works makes to the rector of University the offer on a settlement of conflicting interests of the subordinated worker by submission of the service record in which notes justification of need of application of the chosen action.

The head of the structural unit has the right to address to the Representative for receiving preliminary consultations for a choice of an optimum way of a settlement of conflicting interests.

13. CARRYING OUT INDIVIDUAL CONSULTATION BY THE AUTHORIZED EMPLOYEE OF UNIVERSITY CONCERNING ANTI-CORRUPTION STANDARDS AND PROCEDURES OF CARRYING OUT INCREASE OF THEIR QUALIFICATION IN THE SPHERE OF THE PREVENTION AND COUNTERACTION OF CORRUPTION

From University can address in working hours to the Representative or send to the explanation Authorized the letter of inquiry on granting and the consulting help with questions of prevention and settlement of the conflicts of interests, the prevention and identification of corruption at University.

For formation of appropriate level of anti-corruption culture at employment in University workers get acquainted with requirements of this anti-corruption program and the related documents, and for the acting employees of University periodic information events are held.

Observance by employees of University of the principles and requirements of this anti-corruption program is considered when forming a personnel reserve for promotion to higher positions, and also in case of imposing of disciplinary punishments.

14. AN ORDER OF CARRYING OUT PERIODIC PROFESSIONAL DEVELOPMENT OF EMPLOYEES OF UNIVERSITY IN THE SPHERE OF THE PREVENTION AND COUNTERACTION OF CORRUPTION

Professional development of employees of University is carried out for the purpose of formation at workers of basic knowledge concerning the anti-corruption legislation, overcoming of legal nihilism and legal culture of employees of University.

The representative provides granting in the Educational and methodical complex "Institute of Postdegree Education" of offers on inclusion in the plan of carrying out professional development of employees of University of questions on prevention and counteraction of corruption.

The representative has the right to initiate before the rector of University need of holding seminars, meetings and other actions for the purpose of an explanation of the contents of the anti-corruption legislation to employees of University, increase of understanding of its separate requirements.

In the sphere of prevention of corruption specialists of public authorities and local governments, the public and international organizations can be involved in carrying out actions for professional development.

15. TAKING MEASURES OF REACTION TO THE ELICITED FACTS OF THE CORRUPTION OR CONNECTED WITH CORRUPTION OFFENSES AT UNIVERSITY

In case of identification of the facts testifying to violation of the anti-corruption legislation by the employee of University, the Representative takes the following measures:

• initiates in the order of application of disciplinary punishment established at University in the presence of the sufficient bases;
• initiates in the order of acceptance of the control measures provided by this Anti-corruption program for research of the elicited facts established at University for the purpose of confirmation or a denial of information on probable violation of the anti-corruption legislation by the employee of University;
• informs in accordance with the established procedure specially authorized subjects in the sphere of counteraction of corruption on the revealed violations for acceptance of the measures provided by the legislation by them.

The persons guilty of violation of requirements of this anti-corruption program, and also Law can be attracted to disciplinary, administrative, civil or criminal liability at the initiative of the rector of University, law enforcement agencies or other persons in an order and on the bases provided by the legislation of Ukraine, special regulations and employment contracts.

Disciplinary punishments can be imposed on the employees of University who allowed violations or inadequate implementation of requirements of the anti-corruption legislation according to standards of the labor legislation taking into account defined at University an order.

The university declares that any worker won't be subjected to sanctions (including to release, decrease in a position, to deprivation of an award) if he reported about the estimated fact of corruption, refused to give or get a bribe, to carry out commercial bribery, to provide mediation in bribery, including if such refusal in University was resulted by the missed benefit or wasn't got commercial and competitive advantage.

The person who made the corruption offense or an offense connected with corruption however on which court is applied punishment or isn't imposed on it collectings in the form of deprivation of the right to hold certain positions or to be engaged in the certain activity connected with performance of functions of the state or local government or such that is equated to this activity, is subject to attraction to a disciplinary responsibility.

16. A MODIFICATION ORDER IN THE ANTI-CORRUPTION PROGRAM

At identification not enough effective provisions of this anti-corruption program or the related anti-corruption actions of University, or at change of requirements of the current legislation of Ukraine in the sphere of anti-corruption policy the rector of University will organize development and implementation of the plan of action on revision and change of this anti-corruption program and/or anti-corruption measures.

The anti-corruption program and changes in it are approved by the rector of University and becomes effective its order after its discussion with employees of University.

After her statement, the text of the anti-corruption program is published on the official site of University in a free access.

Changes in the anti-corruption program join in the Collective agreement, employment policies and procedures of University, and also can join in the contracts signed by University with other legal entities.