Compliance – is the conformity of the enterprise and employees with the requirements of the Ukrainian legislation, and in cases of carrying out activities outside Ukraine – foreign legislation, internal production, organizational and administrative documents, as well as other decisions of the company’s management.

Compliance company policy – is  the company’s policy aimed at minimizing legal and reputational risks arising from its violation by employees, regardless of the position held, by persons

who act on behalf of the Enterprise, potential and effective counterparties, professional and ethical requirements, including principles and norms aimed at preventing, detecting, assessing and monitoring corruption risks established by the organizational, administrative and production documents of the enterprise or are expressly provided for by law.

Compliance policy is applied in the day-to-day activities of the Enterprise in the implementation of activities and functions in all structural divisions.

The main circle of persons that the regulation is applied – are employees who work at the enterprise, regardless of the position held and the functions performed.


Compliance policy defines the goals and objectives of compliance at the enterprise, the principles of compliance and key processes.

The policy is a corporate standard of the enterprise and is approved for the effective management of Compliance risks, which is based on the control of the conformity of the enterprise’s activities both in general and with respect to each employee separately with the requirements of the current legislation, rules and standards in force at the enterprise.

The policy is based on the requirements of international legal acts, Ukrainian legislation, corporate standards and includes relevant provisions of foreign standards, recommendations, acts and best practices.

Regulatory and legal framework

  • United Nations Convention against Corruption (UNCAC) (resolution No. A / RES / dated October 31, 2003);
  • Convention on Criminal Responsibility for Corruption of 27 January 1999;
  • Convention on Combating Bribery of Foreign Officials in Concluding International Business Transactions of December 17, 1997;
  • Convention on Combating Bribery of Officials of Foreign States in International Business Transactions of November 21, 1997;
  • The Law of Ukraine “About the fundamentals of preventing and combating corruption”;
  • The Code of Ukraine on Administrative Offenses.


  • Creation and implementation of high culture Compliance policy at the enterprise;
  • Business in compliance with the standards of business ethics and enterprise values;
  • Analyzing and preventing situations in which the requirements of legislation, regulatory requirements and principles of ethical business conduct may not be complied with;
  • Minimize the risk of negative consequences associated with the application of measures to the enterprise for non-compliance with the requirements of legislation, regulatory requirements and principles of ethical business conduct and generally accepted norms of business ethics;
  • Obligations of the employees of the enterprise to know and comply with the principles and requirements of the current Regulation on Compliance policy, the basis of the current anti-corruption legislation and procedures for the prevention of corruption.


The principles that guide the enterprise in the construction and implementation of the Compliance system are:

  • Principle of compliance with business ethics standards.

The enterprise does not recognize illegal, unlawful and non-compliant business ethics as possible for use.

  • Compliance with the best Ukrainian and world practices of Compliance.

The company aspires to comply with the best Ukrainian and world practices Compliance in carrying out its activities.

  • Avoidance of violations in the functioning of the Compliance system.

It provides for the participation of all business units in the construction of the Compliance system, provided that a conflict of interest is prevented by observing a clear definition of roles and responsibilities.

  • Do not interfering with the implementation of the processes when building and implementing the Compliance system.

Resources are allocated for the development, implementation, application, monitoring and continuous improvement of the Compliance system, the organizational and technical means that they use and do not create artificial organizational, political, technical, material constraints and obstacles to the implementation of these processes.

  • Ensuring unimpeded, rapid and unrestricted access to information

Employees who support the compliance system are provided with any information necessary for its operation, taking into account the necessary level of protection of information and information resources in accordance with the requirements of the current legislation.

  • Acceptance and compliance with the agreed requirements of the Compliance system by all employees of the enterprise.

Employees, regardless of their position, recognize, follow and adhere to the established requirements of the Compliance system and require partners to conduct business in accordance with the highest standards of business ethics.

  • Timely and objective elimination of violations.

Employees, regardless of their position and position by all available means, ensure timely identification, objective assessment and timely elimination of Compliance system violations.


  • Management of organizational and ethical standards, norms, values;
  • Doing business in accordance with the highest standards of business ethics and values;
  • Prevention of employees’ conflicts of interest;
  • Implementation of Compliance culture as an integral part of corporate culture;
  • Management of legislative and regulatory requirements;
  • Applying of different approaches to comply with legislative and regulatory requirements;
  • Avoiding the misuse of the insider information;
  • Control of compliance with financial obligations;
  • Countering fraud and corruption;
  • Risk management in the sphere of responsibility of the officials.