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CORRUPTION RESPONSE PROGRAM DEVELOPMENT AND IMPLEMENTATION
According to the Law of Ukraine «About corruption prevention»
No. 1700-VII dated 14.10.2014 Preventing Corruption

What is it?

Corruption response program – is an organization’s action plan, targeted to control and prevent the corruptive offense and offences related to corruption.

Corruption response program must contain:

  • Definition of internal policy on corruption prevention and response in specific area, measures on its implementation as well as measures to meet corruption response strategy and state corruption response program fulfillment;
  • Corruption risk assessment for the institution, organization and the reasons and conditions which allow them to happen;
  • Measures to eliminate detected corruption risks, authorized persons on theirs implementation, terms and required resources;
  • Education and communication about corruption response programs;
  • Procedures to monitor, evaluate an effectiveness and continual review of the programs;
  • Other measures, targeted to prevent the corruptive offense and offences related to corruption.

Corruption response program summarizes the results of corruption risk assessment and measures to prevent (reduce) corruption as well as required resources, authorized persons, terms of and monitoring the plan implementation.

Why do you need it?

Corruption risk assessment and Corription response program development is required by Law of Ukraine «About corruption prevention» dated 14.10.2014 № 1700-VII. According to the Article 61 of the Law «The manager, stakeholders (participants) of a legal entity provide regular corruption risk assessment of its operations and implement appropriate corruption response measures».

Articles 62 and 63 of the law describe in detail all content of corruption response program, which are created taking into account the results of corruption risk assessment and must contain «set of rules, standards and procedures to detect, response and prevent corruption in the legal entity operations».

Corruption response program development will contribute:

  • Strength, integrity and quality of services provided by organization;
  • Improvement of individual honesty, professionalism, ethics and moral values of personnel;
  • Growth of organization’s reputation among community and interested parties;
  • Growth of organization’s effectiveness;
  • Reduce of financial and non-financial losses via corruption offences.

How does Corruption response program development and implementation occur?

The methodological approach on corruption risk assessment and management implies the detailed policies, functions and processes analysis in order to identify and evaluate the potential abilities for corruptive actions (risks) and realistic measures development for theirs elimination or reduction along with regular monitoring and evaluation of effectiveness for implemented measures.

The approach for corruption risk assessment is based on international standard requirements ISO/IEC 31000: 2009 «Risk management – Principles and guidelines», as well as on international experience of such methodologies implementation from Slovenia, Serbia, Montenegro, Australia and USA.

The process of corruption risk assessment consists of 5 interconnected steps:

  1. Preparation and planning of corruption risk assessment
  2. Assessment of corruption risks
  3. Development of the corruption risk response plan
  4. Informing
  5. Monitoring and review

For Corruption response program development it is necessary to detect and describe corruption risks via detailed functions and processes analysis, risk factors and corruption threats definitions and by analyzing existing controls.

Corruption is usually connected to decision making process and appears because of vulnerability to corruption from the process and conditions perspective related to it. Thus we need to analyze main and secondary processes of organization in detail to identify if they are vulnerable to corruption. To define factors and threats of corruption offences each process must be identified, modelled and analyzed.

Risk analysis includes an assessment of likelihood and impact of threats of corruption action taking into account existence and effectiveness of corruption prevention controls. Matching the likelihood, impact and existing controls gives an opportunity to define risk level and risk priority.

Based on corruption risk assessment and analysis results we prepare Corruption risk assessment report, which must contain information regarding function, process and threats of corruption action, existing controls, likelihood and impact levels and resulting risk level.

The response measures definition, i. e. corruption response measures – is the last step in the process of Corruption risk response development. This step assumes the selection of response options, residual risks definition, required resources identification, the goal and indicators to measure results as well as responsible persons for plan implementation, terms compliance and monitoring. All information mentioned above should be represented in Corruption response plan.

Why Active Audit Agency?

Experts of Active audit agency have a unique background of corruption risk assessment, development and implementation of Corruption response plan (corruption response program) projects for several public institutions of Ukraine.

Our experts have developed Guideline for corruption risk assessment and corruption response plan development as a result of that projects with an assistance of Financial sector development program (FINREP-II), which have been provided to Ukraine in 2013 - 2015 with financial support of US Agency for International Development (USAID). The FINREP-II program have been implemented by Financial Markets International, Inc. (FMI) in cooperation of Management Systems International (MSI) and Active audit agency, LLC.

In the guideline the materials prepared by Ministry of Justice of Ukraine were also used regarding corruption risk assessment and corruption response measures in common for public government institutions functions.