Code of conduct

These Rules set forth some basic principles of business conduct and ethics of the Agency employees, which are the basis for internal control and regulation. The rules are advisory in nature, regulating the conduct of the Agency employees, who are required to act with compliance to requirements set out in these Rules. The Agency follows the Rules irrespective of conditions of cooperation with a specific Client or contractor, following common standards. The Rules are designed for all employees of the Agency regardless of position.

The main value of the Agency is its employees

Employment. Equal opportunities for all who have necessary skills, competencies and shares the Agency values. The selection of candidates and remuneration are based on achieved results regardless of race, religion, gender, sexual orientation, citizenship status, national origin and health status. The Agency complies with all the requirements of current legislation regarding employment procedures.

Personal development. The Agency provides all employees with opportunity to contribute to business success through personal involvement and performing interesting duties. Gaining knowledge at workplace and learning during training programs focused on developing specific skills influence the quality of each employee's contribution to the success of the company. The Agency supports equality of opportunity for each employee or job applicant in terms of recruitment, access to training, compensation, career development.

Employee’s documents. The company keeps the documents of employees in non-disclosure mode, making employees familiar with all their personal records, collecting data related only to the creation of personal records, and giving access to authorized persons to use personal records for definite purposes.

The Agency opposes any activity which contracts the rights under the Convention on the Rights of the Child, including Article 32 which requires among other the right of the child to be protected from performing any work that is likely to be hazardous or to interfere with the child's education, or to be harmful to the child's health or physical, mental, spiritual, moral or social development.

Regulatory compliance

The Agency, as well as its contractors/counterparties shall not engage in any illegal activities.

All transactions must be supported by proper documentation. The Agency shall keep proper accounting records and prepare tax returns. Deliberate tax evasion is prohibited.

The Agency supports the use of licensed software and compliance with the relevant conditions of license agreements. It is forbidden to sell or provide access to non-authorized persons to any software or documentation of the Agency.

Materials protected by copyright (e.g. books, music, software and magazines) shall not be copied, distributed or modified without the permission of the copyright owner or authorized person.

Fighting bribery and corruption

The Agency is fully committed to the principles of combating all forms of corruption in Ukraine. We expect all our employees/involved contractors not to accept or offer, directly or indirectly, during the course of their duties money, gifts, services, any other benefits to any government officials, politicians, political parties or any other persons or organizations with a view to inducing them to do or not do something within the scope of, or facilitated by, their job or position.

All payments made on behalf of the Agency must be lawful and aimed solely at legitimate commercial objectives.

The Agency guarantees that the Agency, as well as any of its subcontractors and employees are not involved in any corrupt activities, defined as the abuse of granted authority for the purpose of personal gain, including but not limited to, money laundering, bribery, simplification of payment formalities, embezzlement or money, extortion, favoritism, fraud and obstruction of justice. Offering or giving anything of value to a third party with an inappropriate view may be considered a bribe, and according to current legislation, can result in severe civil and criminal penalties.

Respect for Privacy and Personal Data Protection

Any information that is not publicly available must be protected, even if there is no formal obligation of confidentiality. This applies equally to information about the Agency, its employees and third parties – partners, contractors and clients.

The Agency acquires its competitive advantage mainly due to commercial information, including all documents, know-hows, databases, trademarks, industrial designs and materials in oral or written form. This information is of great value for the business of the Agency and its inappropriate or inadvertent disclosure may not only affect the competitiveness of the Agency, but also lead to unfair competition.

Risks associated with the illegal use of the data files and viruse attacks are a constant threat, affecting all employees. Therefore, the Agency takes all necessary steps to protect this information (regardless of the medium on which it is stored), and to store it in a safe place.

All employees and third parties with whom the Agency has dealings are entitled to their privacy. The Agency adheres to the principles of personal data protection i.e. any information that can be used to identify an individual, whether directly or indirectly (e.g. name, date of birth, social security number, photograph, e-mail address etc.). Personal data protection gives individuals whose data are held the right to control the collection, processing, use, disclosure and storage of data relating to them. These data must be used fairly and for a specific, clear and legitimate purpose, and must only be retained for as long as is necessary for the purpose for which they are processed.

Selection of contractors, partners. Security in dealings with contractors

The Agency dealings with all contractors and partners shall be built on the principles of integrity, ethical standards and mutual trust.

Honesty. Procurement decisions should be based on objective business arguments not on personal relationships or bias, through a fair, honest and transparent process of contractors’ selection. Nobody has the right to obtain an advantage over others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or other unfair actions.

Contractors shall be selected on the basis of open and fair competition; The Agency provides a comparison and evaluation of proposals of all suppliers in a fair manner without an evidence of favoritism.

The Agency ensures that all contractors, regardless of services they provide, understand and respect the Agency values and ethical principles.

The Agency on a timely manner and in accordance with the agreed procedures carries out payments to contractors.

The Agency protects confidential information of partners at the same degree as their own.

Conflicts of interest. The Agency requires our contractors and suppliers to inform of any conflict of interest that might affect their performance of contracts or services on behalf of the Agency.