Anti-corruption policy
Operator of the authorized electronic marketplace Zakupivli.Pro
Preamble
LIMITED LIABILITY COMPANY "ZAKUPIVLI.PRO" (hereinafter — the Operator) conducts its activities based on the principles of integrity, transparency, legality, accountability, fairness, and zero tolerance for corruption.
The Operator adheres to the principles of "Tone from the Top" and zero tolerance for corruption, implements a risk-based approach, ensures the protection of whistleblowers, and continuously improves the system.
1. General provisions
1.1. Purpose and objectives of the Policy
This Anti-corruption Policy (hereinafter — the Policy) defines the core principles, standards, rules, and mechanisms for preventing corruption and bribery, ensuring ethical conduct, developing a culture of integrity, managing corruption and reputational risks, upholding the principles of transparent and fair competition, identifying and resolving conflicts of interest, and responding to reports of violations, thereby ensuring proper interaction between the Operator and system users, counterparties, and other market participants.
The Policy is aimed not only at the formal fulfillment of legal requirements but also at establishing a systemic approach to integrity, ethics, and compliance as an integral part of the Operator's activities.
1.2. Regulatory basis of the Policy
The Policy has been developed taking into account:
- the Law of Ukraine "On Prevention of Corruption";
- the Law of Ukraine "On Public Procurement";
- the Law of Ukraine "On Protection of Economic Competition";
- internal requirements and principles governing the operation of the electronic procurement system (including the requirements of SE "PROZORRO").
1.3. Scope of application
This Policy applies to the Operator's management, the Operator's employees, representatives, contractors, persons acting on behalf of the Operator, counterparties, and partners with respect to their interaction with the Operator.
The Operator's management ensures that employees and other persons are properly familiarized with the requirements of this Policy.
2. Core principles of operation
2.1. Zero tolerance
The Operator adheres to a zero-tolerance principle toward bribery, the receipt and/or provision of undue benefit, conflicts of interest, hidden influence, manipulation, unfair competition, and any other manifestations of unethical or dishonest conduct.
No economic benefit, competitive advantage, or commercial interest may serve as grounds for violating the law, the principles of integrity, or the requirements of this Policy.
2.2. Legality
The Operator conducts its activities solely in accordance with the legislation of Ukraine, the rules governing the operation of the electronic procurement system, the regulatory and administrative acts of SE "PROZORRO", contractual obligations, and internal procedures.
2.3. Integrity
Integrity is regarded as one of the key elements of trust in the public procurement system and in the Operator's services. The Operator ensures honest conduct, openness, accountability, the prevention of hidden influence, and compliance with ethical standards.
2.4. Transparency
The Operator ensures the accuracy of the information provided, open communication, proper documentation of processes, and fosters a transparent environment of interaction.
2.5. Fair competition
The Operator supports a competitive environment based on service quality, professionalism, and ethical conduct.
The Operator does not tolerate the discrediting of other operators, anti-competitive concerted actions, any manipulation, the spread of false information, or unethical competitive practices.
3. Anti-corruption system
3.1. Anti-corruption due diligence checks
The Operator conducts due diligence checks on counterparties, partners, employees, representatives, consultants, and other involved persons.
The check may include an analysis of business reputation, a check for the presence of sanctions, an assessment of conflict-of-interest risk, an analysis of court decisions (including in criminal proceedings and corruption-offense cases), as well as a general analysis of corruption risks.
The purpose of the check is to minimize corruption and reputational risks, as well as the risk of being unable to cooperate with dishonest counterparties.
4. Standards of ethical conduct
4.1. Prohibition of bribery and undue benefit
Employees and representatives of the Operator are prohibited from offering, providing, or receiving undue benefit, making hidden payments, using intermediaries to commit corrupt acts, exerting undue influence on the decisions of officials, creating artificial advantages, or using their official position for private interests. This prohibition applies to both direct and indirect forms of influence.
4.2. Gifts and business hospitality
Gifts and business hospitality are permitted only if they are consistent with generally accepted notions of hospitality, do not affect impartiality, do not create an obligation to perform certain actions, and comply with the legislation of Ukraine and ethical standards.
Excessive or expensive gifts, hidden incentives, recurring benefits, or gifts given in exchange for a decision in favor of the giver are strictly prohibited.
4.3. Conflict of interest
Persons covered by this Policy are obliged to take measures to prevent conflicts of interest from arising, to report an existing or potential conflict of interest in writing, to refrain from making decisions under a conflict of interest, and to prevent private interests from affecting the professional performance of their duties.
A hidden conflict of interest is regarded as one of the key integrity risks.
5. Reporting violations and response procedure
5.1. General provisions
The Operator supports the principle of open and good-faith reporting of possible corrupt practices, conflicts of interest, dishonest conduct, or violations of this Policy.
The reporting mechanism is aimed at the timely identification of risks and the protection of reputation.
5.2. Reporting channels
Reports may be submitted:
- to the Operator's email address [email protected];
- in writing to the postal address: 02121, Kyiv, Kharkivske Shose, building 201-203, lit. 3B.
Reports may be:
- open;
- confidential;
- anonymous.
5.3. Requirements for a report
A report should contain a description of the circumstances of the event, the date or period when it occurred, information about the possible violation and the persons involved, as well as (if available) a list of evidence that can be verified.
5.4. Materials that may confirm a violation
The following may serve as evidence:
- business correspondence;
- electronic messages;
- screenshots;
- copies of documents;
- technical data;
- explanations from individuals;
- publications;
- other materials.
5.5. Review and response measures
For every registered report, the Operator's authorized person conducts a preliminary analysis and investigation while ensuring confidentiality and impartiality.
Based on the results of the review, response measures may be applied: issuing recommendations, disciplinary sanctions, revising or terminating cooperation with a counterparty, and, if signs of a crime are identified, referring the materials to law enforcement authorities.
5.6. Prohibition of abuse
The reporting mechanism may not be used as a tool of unfair competitive struggle, for discrediting, spreading knowingly false information, or settling personal scores.
6. Protection of whistleblowers
Persons who, in good faith, report violations of this Policy or corruption offenses are protected in accordance with the legislation of Ukraine.
The Operator guarantees the confidentiality of the whistleblower's identity and restricted access to the review materials, and strictly prohibits any form of persecution, discrimination, or pressure against such employees or partners.
7. Training and culture of integrity
The Operator ensures regular briefing and training of employees on the requirements of the law and this Policy, develops an internal culture of integrity, promotes ethical standards, and raises awareness of minimizing corruption risks in its operations.
8. Leadership commitment
The Operator's management demonstrates personal commitment to the principles of integrity, allocates the resources necessary to implement this Policy, supports the operation of reporting channels, ensures objective reviews are conducted, and does not allow any pressure on persons responsible for compliance.
9. Interaction with business partners
The Operator extends the principles of integrity to its counterparties and partners. To this end, the Operator may use anti-corruption clauses in contracts, conduct business reputation checks, and reserves the right to unilaterally terminate cooperation if facts of dishonest or corrupt conduct on the part of a counterparty are identified.
10. Management of corruption risks
The Operator periodically identifies, assesses, and analyzes corruption risks in its own business processes, implements control mechanisms to minimize them, and reviews its risk assessment whenever legislation or operational activities change.
11. Monitoring and improvement
The Operator monitors the effectiveness of the anti-corruption measures implemented, analyzes identified violations, evaluates the effectiveness of internal controls, and periodically updates its procedures in line with changes in Ukrainian legislation and compliance best practices.
12. Final provisions
This Policy forms the basis of the Operator's integrity system and is aimed at maintaining a high level of trust in the zakupivli.pro electronic marketplace, ensuring transparent and honest interaction with users, minimizing corruption and reputational risks, and developing a culture of responsible partnership.