Anti-Corruption Policy

Updated: April 26, 2026

The PUBLIC UNION “UKRAINIAN ASSOCIATION OF STARTUPS”
(UKRAINIAN ASSOCIATION OF STARTUPS) adheres to a principle of zero tolerance for corruption in any form.

This Anti-Corruption Policy is a public declaration of our position and sets out the basic principles of integrity, transparency, and responsible conduct in relations with partners, donors, programme participants, consultants, institutional representatives, and other stakeholders.

1. Our Position

We do not tolerate:

• bribery in any form;
• the promise, offer, giving, or receipt of an undue advantage;
• so-called facilitation payments;
• kickbacks, hidden rewards, or informal payments;
• abuse of authority or status for personal gain;
• undisclosed conflicts of interest;
• manipulation of financial data, reporting, documentation, or performance results;
• use of the organisation’s resources contrary to its statutory goals or declared integrity principles.

2. Scope of Application

This policy applies to the public activities of the organisation, as well as to interactions carried out on its behalf or in connection with its projects, programmes, partnerships, events, communications, and the use of organisational resources.

3. Gifts, Hospitality, and Courtesy Benefits

We do not allow gifts, services, rewards, hospitality, or other benefits if they:

• may influence, or appear to influence, decision-making;
• are provided in exchange for an action, omission, facilitation, or advantage;
• are non-transparent, unjustified, or excessive;
• contradict the law, internal rules of the parties, or principles of integrity.

Symbolic and reasonable business courtesies may be acceptable only where they do not create a conflict of interest, are not connected with obtaining an improper advantage, and do not harm the organisation’s reputation.

4. Conflict of Interest

We expect real, potential, and perceived conflicts of interest to be identified and addressed in good faith.

Persons acting on behalf of the organisation or in connection with its activities should refrain from participating in decisions, processes, or arrangements where their private interest may affect objectivity, impartiality, or trust in such decisions.

5. Transparency and Integrity in Activities

The organisation seeks to ensure:

• good-faith use of resources;
• transparent communication and documentation;
• accurate financial and project reporting;
• proper compliance with partnership, grant, and donor obligations;
• prevention of hidden payments, unofficial arrangements, or manipulation of results.

6. Reporting Possible Violations

If you become aware of possible corruption, corruption-related misconduct, violations of integrity principles, or other substantial breaches of this policy, you may report them to:

[email protected]

Reports should preferably include as much detail as possible:

• what happened;
• when and under what circumstances;
• who was involved;
• what documents, data, or other facts may support the information provided.

We accept reports in good faith and review them as confidentially as possible, taking into account the law, the content of the report, and the need to verify facts.

7. Confidentiality and Protection Against Retaliation

We do not support retaliation, pressure, discrimination, threats, or any other adverse consequences against persons who in good faith report possible violations.

To the extent possible, we seek to treat such reports confidentially and to avoid improper disclosure of the identity of the reporting person, unless otherwise required by law or necessary for the handling of the report.

8. Anonymous and External Reporting

Where the law provides other available channels for reporting, a person may also use them in accordance with the laws of Ukraine.

9. Review of Reports and Response Measures

The organisation reserves the right to:

• conduct a preliminary assessment of the report received;
• request additional clarification or materials;
• carry out an internal review within its available authority;
• contact competent authorities where necessary;
• take response measures if a violation is confirmed.

10. Consequences of Violations

If a breach of this policy or signs of corrupt conduct are established, the organisation may, depending on the nature of the situation:

• terminate or revise cooperation;
• deny further participation in initiatives, projects, or partnerships;
• initiate internal restrictive measures;
• transfer information to competent authorities;
• take other actions not prohibited by law and necessary to protect the reputation, resources, and lawful activities of the organisation.

11. Good Faith of Reports

We expect reports of possible violations to be submitted in good faith and based on a belief in the accuracy of the reported facts. Knowingly false, manipulative, or defamatory reports are contrary to the principles of this policy.

12. Updates to This Policy

We may update this Anti-Corruption Policy from time to time to reflect changes in legislation, integrity practices, partner requirements, or the specific nature of the organisation’s activities. The current version is always published on this page with the date of the latest update.

13. Contact Information

For all questions related to this Anti-Corruption Policy or reports of possible violations, please contact:

[email protected]