I.P.Cert LLC (hereinafter – “the Company”) takes issues of combating corruption and bribery seriously and complies with all applicable legislative and regulatory requirements. This Anti-Corruption and Anti-Bribery Policy P0-Pa001:2025 (hereinafter – “the Policy”) has been developed in accordance with ISO 37001 standard, the Law of Ukraine “On Prevention of Corruption” (hereinafter – “the Law”), Methodological recommendations on the application of certain provisions of the Law of Ukraine “On Prevention of Corruption” regarding prevention and settlement of conflicts of interest, and other relevant regulatory requirements, and taking into account obligations enshrined in the Agreement on the creation of an initiative based on principles of transparency and anti-corruption.
It is very important that every Company employee reads, understands and acts in accordance with the provisions of this Policy.
This Policy applies to all Company employees of all levels and positions, directors, managers, employees (full-time, temporary or those working under fixed-term employment contracts) (collectively referred to as “employees” in this Policy), as well as all persons acting on behalf of the Company, including consultants, contractors, seconded employees, outsourced employees, interns, agents and any other persons associated with the Company. Partner companies are recommended to apply similar policies and relevant procedures for preventing bribery.
Corruption – Abuse of entrusted powers for private purposes, leading to unfair competition and loss of financial and social resources.
Bribe – any benefit, monetary or otherwise, offered, promised or given to public officials or any company employees.
Bribery – receipt of a bribe by an official person, as well as giving them a bribe in order to obtain certain benefits in an unlawful manner.
Offense – according to this Policy – is considered (1) bribing another person; (2) receiving a bribe; (3) bribing a public official; (4) failure by the Company to take actions necessary to prevent bribery (Law “On Prevention of Corruption”).
Trade Secret – information that is secret in the sense that it as a whole or in a certain form and combination of its components is unknown and not easily accessible to persons who usually deal with the type of information to which it belongs, has commercial value due to this and has been subject to adequate measures to preserve its secrecy taken by the person who legally controls this information under the existing circumstances.
Improper performance of duties by a person – cases of (1) dishonest actions, (2) biased judgments or (3) abuse of power by a person holding a position of authority.
Bribery – in the context of this Policy – is a situation where one person offers, makes payment, demands or accepts payment, gift, service, financial or other benefits from another person in order to influence the course and results of business activities or to encourage or reward improper performance of duties.
Bribery and corruption affecting public officials or commercial enterprises, including joint ventures, may be direct or indirect through the involvement of third parties such as agents, brokers, consultants and joint venture partners.
“Kickback” – is a payment made in response to receiving a certain business benefit or advantage. Company employees must avoid any actions that may lead to payment/receipt or assumptions about the possibility of payment/receipt of “kickbacks”/facilitation payments by the Company.
Facilitation payment – small informal payments to public officials made to guarantee or accelerate the passage of established state procedures.
Gift – money or other property, benefits, privileges, services, intangible assets that are given/received free of charge or at a price below the minimum market price.
“Third party” – in the context of this Policy – any natural or legal person with whom Company employees interact in the course of work, consisting of: existing and potential clients, suppliers, distributors, persons with whom the Company has business relationships, agents, consultants, advisors, state and public authorities (including consultants, representatives and officials), as well as politicians and political parties.
Associated person – a concept that may include any person providing services to the Company and on its behalf. Considering all possible circumstances, associated persons may be employees, subsidiaries and partners.
Honest and ethical business conduct is the Company’s policy. We adhere to a strict approach in matters of combating bribery and corruption and are committed to standards of professional, honest and decent business activities and relationships in all areas of the Company’s operations.
Application of a strict approach in matters of combating bribery and corruption by all persons with whom the Company has business relations.
Zero tolerance for corruption: I.P.Cert LLC strictly prohibits any forms of corruption, including bribery, both within the Company and in relations with third parties.
Compliance with legislation: All employees, partners and counterparties of the Company are obliged to comply with the current legislation of Ukraine regarding prevention of corruption and bribery.
Compliance with trade secrets: All Company employees are obliged to comply with current legislation regarding compliance with trade secrets. The requirement to comply with trade secrets is prescribed in the Agreement on non-disclosure of trade secrets and anti-corruption, which is concluded with each employee upon employment. The requirement to comply with trade secrets is regulated by the specified Agreement. A non-exhaustive list of information that may be considered a trade secret is provided in Appendix 2 to this Policy and the Agreement on non-disclosure of trade secrets and anti-corruption, which is signed with Company employees and, if necessary, with suppliers of goods/services or clients.
Prohibition of bribery: Company employees are prohibited from offering, promising or giving bribes to any persons. It is also prohibited to receive or demand bribes.
Transparency: The Company ensures transparency in all business processes and interaction with third parties. All financial operations must be documented and available for verification, including carefully recording all expenses related to sponsorship activities, including donations and charitable contributions, in the Company’s financial reporting.
Resolution of conflicts of interest: Employees are obliged to report any potential or actual conflicts of interest that may affect their objectivity and impartiality in decision-making.
Responsibility: Each employee bears personal responsibility for compliance with this Policy and reporting any violations.
Training and awareness raising: The Company provides regular training for employees on anti-corruption legislation and business ethics.
The principles of anti-corruption and anti-fraud that the Company adheres to in accordance with the Memorandum with the UN Global Compact in Ukraine and representatives of business, community and state bodies are set out in Appendix 1 of this Policy.
The Company takes its legal and reputational responsibility extremely seriously and expects a similar approach from its employees.
6.1 It is prohibited to offer, promise or provide financial or other benefits to any persons (including public officials) in order to induce or encourage improper performance of their official duties.
6.2 It is prohibited to directly or indirectly accept or consent to receive financial or other benefits as remuneration for improper performance of one’s official duties. It does not matter to whom such benefit is intended – directly to you or to a third party.
6.3 If an employee’s position provides for this, they are allowed to organize and participate in representative events/corporate hospitality (for clarification on this issue, the employee should contact their immediate supervisor). However, such events should always be reasonable and proportionate. More detailed information on this issue (including rules for exchanging business gifts) is set out in the following sections of the Policy.
6.4 Every Company employee must read, understand and ensure constant compliance of their actions with the provisions of this Policy.
6.5 The employee is obliged to inform their immediate supervisor about received/given business gifts and corporate hospitality (if possible, in advance or immediately after receiving/giving a gift or corporate hospitality).
6.6 All persons working in the Company or under its control are obliged to take measures to prevent, detect and report facts of bribery, as well as other forms of corruption. All employees are obliged to avoid any actions that could potentially lead to violation of the provisions of this Policy.
6.7 If an employee is certain or suspects that any action currently or in the future may violate or contradict the provisions of this Policy, they are obliged to immediately notify the Company director. For example, if a client or potential client offers something to an employee in order to obtain business benefit from the Company or talks about the need to give a gift or monetary reward for the opportunity to cooperate with them.
6.8 Disciplinary measures, up to dismissal, may be applied to any employee who violates this Policy. Taking into account labor legislation, the Company reserves the right to terminate employment relations with employees in case they violate this Policy.
6.9 Persons who do not comply with legislation may bear administrative or criminal responsibility.
6.9.1 Administrative responsibility:
6.9.2 Criminal responsibility
If the purpose of the gift is to influence the actions or inaction of an employee using their official position, such actions are qualified as a crime, punishment for which is provided by Article 368 of the Criminal Code of Ukraine.
6.10 Possible scenarios for implementing bribery and corruption risks that Company employees should avoid are set out in Appendix 2 of this Policy.
7.1 The Company director bears primary responsibility for implementing procedures that prevent bribery and corrupt activities and reports on the results of compliance with this policy at least once a year to all Company employees.
7.2 Company management is responsible for daily application of this Policy in work processes, as well as checking the Policy for compliance with legislative requirements, adequacy and effectiveness. Management and senior staff at all levels are responsible for bringing the requirements of this Policy to the attention and understanding of their subordinates. Any identified opportunities for improving work activities should be implemented without delay and are subject to regular review to ensure their effectiveness.
7.3 All Company employees bear individual and collective responsibility for successful application of this Policy and are obliged to follow the procedures described in the Policy. If an employee sees opportunities to improve this Policy, they should contact their immediate supervisor with questions, comments and suggestions on such matters.
8.1 Risk assessment: Regular risk assessment related to corruption and bribery to identify possible vulnerable areas in the Company’s activities.
8.2 Monitoring and audit: Monitoring and periodic audits to verify compliance with this Policy and identify possible violations.
8.3 Reporting procedure: Implementation of a mechanism for anonymous reporting of possible violations without fear of reprisals. The Company ensures confidentiality and protection of persons who report violations.
8.4 Taking measures: Correcting identified violations, including possible disciplinary action or dismissal of employees, as well as taking appropriate measures regarding third parties.
9.1 All measures for providing professional services, such as scientific and consulting services, must be documented in writing that clearly describes the services provided. All remuneration must have a reasonable ratio to the market value of the services provided and must be specified in fixed amounts, not percentages. Services must be adequately documented through specific “results” provided in each case, such as reports or memoranda.
9.2 The Company may make contributions to remuneration, which should not exceed fair market prices, for industry specialists or scientists who make presentations at educational meetings or conferences.
9.3 The Company may pay reasonable travel, accommodation and related expenses on behalf of its clients’ personnel and other industry specialists in connection with invitations to meetings or conferences devoted to educational or training purposes. If any Party or representative of any Party has a policy with more restrictive norms, the more restrictive policy will prevail. Any related or entertainment expenses must be subordinated to the educational or training purposes of the meeting or conference in time, scope and purpose.
9.4 The Company undertakes to avoid tender bid falsifications and participation in tender bid falsifications, including falsifications or “distortions” of tender bid specifications and technical, commercial and/or financial conditions of tender bids.
9.5 The Company undertakes to refrain from using “false or deceptive” advertising methods and claims aimed at inducing incorrect perception of the Party’s products or third-party goods.
This Policy does not prohibit reasonable and appropriate exchange of business gifts with third parties, as well as corporate hospitality. However, any received or given gifts must comply with the provisions of this Policy.
This Policy allows giving and receiving business gifts on behalf of the Company that comply with generally accepted notions of hospitality (Part 2 of Article 23 of the law), under the following conditions:
Permitted gifts:
It is allowed to receive (Part 2 of Article 23 of the Law): publicly available discounts on goods, services, publicly available winnings, prizes, awards, bonuses; any gifts from close persons regardless of their value.
After receiving a permitted gift, a person is obliged not to make decisions and not perform actions in favor of the person from whom such gift was received.
A decision made by a person in favor of a person from whom they or their close persons received a gift is considered to be made under conditions of conflict of interest. Such decisions are subject to cancellation.
Although the Policy provides for cases in which receiving a business gift is considered acceptable, when making a decision about the appropriateness and justification of a gift, Company employees must always consider all existing circumstances. In each individual case, the employee must consider the intentions related to the gift and assess whether the giving of the gift is related to the desire to induce them to improper performance of official duties. All given or received gifts must be registered in the appropriate Journal.
Prohibited gifts:
It is categorically prohibited to demand, ask for, receive gifts (regardless of their value) for oneself or close persons from legal entities and individuals:
It is unacceptable when a Company employee (or another person on their behalf):
11.1 The Company does not make or accept any types of “kickbacks” or facilitation payments.
11.2 If a Company employee is asked to make a payment on behalf of the Company, they must always consider the purpose of the payment and the proportionality of the requested amount to the cost of goods or services provided in return. Company employees must always demand provision of an invoice indicating the purpose of the payment. In case of any suspicions, concerns or doubts about the payment, the employee must contact their immediate supervisor.
11.3 Since legislation prohibits facilitation payments and “kickbacks,” employees should not perform such actions. Any incidents of this nature or inducement to them must be reported to the supervisor at the first opportunity.
The Company does not make contributions in favor of political parties. The Company makes exclusively contributions for charitable purposes that do not contradict the norms of current legislation and ethics. Under no circumstances can contributions be made without obtaining prior agreement from the Company director.
The following provisions should be taken into account when cooperating with associated persons:
14.1 Employee obligations: All employees must confirm their compliance with the anti-corruption and anti-fraud policy through signing and complying with relevant provisions (self-attestation) and undergoing training.
14.2 Training: The Company provides regular training for all employees on the requirements of this policy and current anti-corruption norms.
14.3 Verification and audit: The Company conducts regular verifications and audits to ensure compliance with anti-corruption norms and identify potential violations.
14.4 Reporting violations: Employees and partners must immediately report any violations of the anti-corruption policy or suspicions of corrupt actions through established channels: by sending an email to hello@ipcert.net.
14.5 Policy updates: The anti-corruption and anti-bribery policy will be regularly reviewed and updated to correspond to changes in legislation and internal needs of the Company.
15.1 Company management and Team Leaders must every 12 months independently confirm that they have complied with the provisions of this Policy, and that they are not aware of any bribes given, offered or received by any Company employees or third parties on behalf of the Company.
15.2 All significant contractors and consultants providing services to the Company or on its behalf must every 12 months independently confirm that they have complied with the provisions of this Policy and that they are not aware of any bribes offered or received regarding the services provided.
16.1 The Company must maintain financial reporting and apply appropriate internal control procedures to confirm the business necessity of making payments to third parties.
16.2 Employees are obliged to ensure preparation of all reports on spending on corporate hospitality, business gifts and other expenses related to third parties.
16.3 All accounts, invoices, explanatory notes and other documents and records related to relationships with third parties such as clients, suppliers and business partners must be conducted accurately and completely. Accounts cannot be accounted for “off-balance” in order to facilitate or conceal unlawful payments.
16.4 The Company is obliged to maintain a Journal of all given and received business gifts and corporate hospitality. If an employee receives a gift or participates in an entertainment representative event, they are obliged to immediately notify the responsible employee by email for entering this information into the Journal. This journal is subject to periodic checks, including by management.
The Company encourages employees to report any suspicions or information they may have that could be related to unlawful actions as early as possible. If an employee is not sure whether a certain action is a manifestation of bribery or corruption, or has any other doubts, they should contact the Company director for clarification.
Contact information: Any questions or reports of policy violations should be sent to email hello@ipcert.net or to the address: 40-V Hlybochytska St., office 3A, Kyiv, 04050.
Employees who refused to accept or offer a bribe, reported their suspicions of corruption or misconduct of other persons sometimes fear possible consequences. The Company encourages openness in such matters and will support any person who reports their concerns about non-compliance with this Policy, even if such concerns prove to be mistaken.
19.1 Company management controls the effectiveness of implementing this Policy, as well as checks it for compliance with requirements, adequacy and effectiveness. Any identified opportunities for improvement should be implemented without delay.
19.2 All Company employees are responsible for successful application of this Policy and must be guided by it when disclosing information about any potential threats/risks or offenses.
19.3 The Company reserves the right at its own discretion to change and/or amend the provisions of this Policy from time to time.
20.1 Investigation: All reports of policy violations will be investigated with observance of confidentiality and fairness.
20.2 Responsibility: Violations of the anti-corruption policy provide for appropriate disciplinary sanctions, including possible dismissal and/or legal liability.
The Memorandum between the UN Global Compact in Ukraine and representatives of business, community and state bodies is hereinafter referred to as the Initiative. Each of the aforementioned parties is hereinafter referred to individually as a “Party,” and collectively as “Parties.”
I.P.Cert LLC (hereinafter – the Company) undertakes to:
Conduct its business activities honestly, transparently and in full compliance with the legislation of Ukraine, the principles of the United Nations Convention against Corruption (UNCAC), the Inter-American Convention against Corruption, the International Chamber of Commerce (ICC) Rules on Combating Corruption, as well as the Tenth Principle of the UN Global Compact relating to corruption.
Refrain from paying bribes and not allow its directors, employees, other officials of the Company and third parties (including intermediaries, “trade agents,” sales representatives, commercial consultants, etc.) to pay bribes on its behalf.
Avoid improper influence on any decisions of the Company by refraining from receiving bribes and not allowing its directors, employees, other company officials and third parties (including intermediaries, “trade agents,” sales representatives, commercial consultants, etc.) to receive bribes on its behalf.
Avoid tender bid rigging and participation in tender bid rigging, including falsifications or “distortions” of tender bid specifications and technical, commercial and/or financial conditions of tender bids.
Refrain from making contributions in connection with local political campaigns.
Carefully record all expenses related to sponsorship activities, including donations and charitable contributions, in the company’s financial reporting.
Bring products/services to market in accordance with quality and integrity statements set forth in advertising and product descriptions. In addition to ensuring consistency between products and their descriptions, the Company will not sell products in which undesirable substances exceed specified limits, or exceed the Company’s statements regarding pollutants in products. Since the Company’s products and production facilities must be registered, commercialization of all products must be conducted, in all respects, in accordance with norms and rules whose compliance is ensured by current legislation.
The list below includes issues that constitute trade secrets. This list is not final or exhaustive and is provided solely to help employees comply with the provisions of this Policy.
