ANTI-CORRUPTION PROGRAM OF LEGAL ENTITY: CONCEPT, CONTENT AND DISCUSSION QUESTIONS
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Abstract
The article examines the nature of the anti-corruption program of a legal entity, its normative support and the implementation process. In Ukraine there is no theoretical development of the problem of implementation and implementation of the anti-corruption program of legal entities. When developing and implementing an anticorruption program, enterprises use the Law of Ukraine "On Prevention of Corruption", the Typical Anti-Corruption Program of a Legal Entity and Methodological Recommendations on the Preparation and Implementation of Anti-Corruption Programs of Legal Persons developed by the National Agency of Corruption Prevention. However, these documents contain some discussion questions that require additional clarification and explanation.
The purpose of this article is a comprehensive analysis of the norms governing the development of the implementation and implementation of the anti-corruption program of a legal entity and its improvement.The content of the anti-corruption program is analyzed in detail, and discussion issues are identified that require additional consideration and resolution. Proposals for improving the anti-corruption program itself and its process of its adoption and implementation are developed. Though the content of the anti-corruption program reflects most of the discussion issues and issues related to the prevention and counteraction of corruption in the enterprise, in our opinion, there are still some aspects of the company's activity, which require clearer clarification and regulation.
According to the authors, special attention should be paid to regulating the interaction of a legal entity with civil servants, business partners and intermediaries. In more detail, it is necessary to consider actions of legal entity employees in case of extortion of unlawful benefits from both civil servants and other legal entities, disciplinary responsibility for violating the anticorruption program by both employees and business partners of a legal entity.
In addition, the anti-corruption legislation should clearly indicate that the NACC's Standard Anti-corruption Program for a legal entity is a set of minimum standards, the observance of which is mandatory for the compliance of the legal entity with anti-corruption principles.
Keywords: corruption, anti-corruption program, anticorruption program of a legal entity, anti-corruption measures, implementation of anti-corruption program
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