+380 44 3777361

+380 44 3777362

8 Illinska str.
Kyiv, Ukraine, 04070

Anti-corruption and bribery policy

Anti-corruption policy of PLP Law Group (the Firm) is aimed at running business based on fair and ethical conduct in relations with employees and third parties. As part of this, the Firm has a policy of zero tolerance bribery and corruption and seeks to act professionally, responsibly and in good faith in all business relationships and areas of practice in compliance and ensuring effective mechanisms for prevention of corruption and combating bribery.

The Firm complies with all regulatory acts relating to anti-bribery and corruption, both in Ukraine (Act on Prevention of Corruption) and in other jurisdictions in which it operates (U.S. FCPA, UK Bribery Act etc.).

In this policy Third Party means any natural person or organization with whom we come in contact providing services and managing business, and includes actual or potential clients and customers, agents, suppliers, contractors, agents, consultants and government agencies and organizations, local authorities, including their representatives and officials, politicians and political parties.

This policy applies to all persons working in the Firm of all ranks, including partners, directors, advisors, attorneys and other employees (working on a permanent and temporary basis or part-time), consultants, contractors, interns, volunteers, agents or any other person associated with the Firm (collectively referred to as Workers in this policy).

Countering Bribery

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Bribery is a criminal offense and means offering or giving a bribe receiving or request / demand bribes.

The Firm is aware of its responsibility in combating corruption and bribery, and risks associated with possible involvement of Workers in such illegal activities.

Gifts and hospitality

This policy does not prohibit the normal ethical behavior that provides relevant hospitality, friendliness, courtesy, including the transfer and receipt of gifts, treats and free provision of services. However, we have specific internal policies and procedures to ensure the correct and unambiguous understanding by the employee, what should be regarded as normal ethical behavior on the basis of financial constraints and principles set out below (basic principles), namely that any gifts:

  • should not be made to encourage certain actions or omissions, or would result in the emergence of advantage or prejudice, or could be regarded as a bribe;
  • must comply with local laws, customs business etiquette;
  • must be given in the name of organization, not in the name of the individual;
  • must not include cash or a cash equivalent;
  • must be reasonable and appropriate under the circumstances;
  • must meet the conventional sense on characteristics for such gifts including cost, occasion;
  • must be given openly, not secretly.

In any case the gifts should not be offered to or accepted from persons in positions of authority of state power or local government, or their representatives or politicians or political parties without the prior consent of the Firm’s partner.

The practice of giving gifts can vary between countries and regions, and what can be normal and acceptable in one region may in no case be presented elsewhere. Gift or hospitality should be considered in the context of the circumstances in terms of relevance and justification. Also be assessed and taken into account the true intentions for gift or hospitality.

It is not acceptable for any Worker (or someone on their behalf) to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;
  • accept payment from third parties for which known beforehand or can reasonably assume that such payment involves receiving benefits;
  • accept a gift from a third party where it is known or suspected that it is offered with the expectation that it will obtain a business advantage for them;
  • threaten or persecute another Worker who refused to participate in bribery or exposed the fact of bribery, and expressed concern about compliance with this policy;
  • engage in any activity that may lead to a breach of this policy.

Facilitation payments and "kickbacks"

We do not make, and do not accept, facilitation payments or "kickbacks" of any kind, such as small, unofficial payments made to secure or expedite routine procedures, or payments made in return for a business advantage.

Donations

The Firm makes charitable donations that are legal and ethical under local laws.

Duties and responsibilities

For prevention, detection and notification of bribery and other forms of corruption are responsible all the individuals who work for us or are under our control. Workers should avoid any activity that may violate this policy.

The Worker must notify the Firm as soon as possible if there is a situation or may occur in the future, that is inconsistent with this policy, if someone requires from him a bribe or someone offers a bribe, or he believes that it is about involving in other type of illegal activity.

To the Worker who violates this policy may be applied disciplinary measures that may lead to dismissal. We reserve the right to terminate our contracts with third parties, if their actions have corruption component and can damage the reputation of the Firm.

If any person will be aware of the circumstances concerning the actions of our Workers or Third Parties who have evidence of corruption or violation of this policy, he can report the facts directly to one of the partners of the Firm.

Training and communication

Training on this policy is provided for all Workers

for awareness on proper compliance with this policy and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to Third Parties.

Monitoring and control

The Firm constantly monitors and controls the implementation of this policy at regular basis, analyzing its application in terms of relevance, adequacy and effectiveness. Internal control systems and procedures are also subject to regular review to ensure confidence that they are effective in combating bribery and corruption.

All our Workers are aware that they are responsible for the successful implementation of this policy and have to use it for uncompromising detection and combating corruption.