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ANTI-CORRUPTION POLICY

ANTI-CORRUPTION POLICY OF LLC “EDUCATIONAL AND TRAINING CENTER”

Terms and definitions.

Corruption – is the illegal use by a person of his official or official position for the purpose of obtaining a material or non-material benefit in his personal interests or in the interests of other persons, as well as the illegal provision of such a benefit;

A corruption offence – is an act that has the characteristics of corruption, for the commission of which the law provides for liability;

A conflict of interest – is a situation in which personal interest (direct or indirect) affects or may affect the proper performance of official or official duties by a person and in which a contradiction arises or may arise between personal interest and the rights and legitimate interests of citizens, organizations, society or the state.

THE ANTI-CORRUPTION POLICY OF LLC “EDUCATIONAL AND TRAINING CENTER” (HEREINAFTER LLC) REFLECTS THE ORGANIZATION’S COMMITMENT TO THE LAW AND HIGH ETHICAL STANDARDS IN BUSINESS RELATIONS, AS WELL AS THE LLC’S DESIRE TO IMPROVE ITS CORPORATE CULTURE AND STRENGTHEN ITS BUSINESS REPUTATION.

1. Basic principles of anti-corruption policy.

  • The principle of compliance of the Anti-Corruption Policy of the LLC with the current legislation of the Republic of Uzbekistan and generally accepted norms of corporate relations.
  • The principle of personal example of the management. The management of the LLC plays a key role in the formation of a culture of intolerance to corruption and the creation of an internal organizational system for preventing and combating corruption.
  • The principle of employee involvement. The employees are familiar with the Anti-Corruption Policy of the LLC, and are also informed on a permanent and systematic basis about the provisions of the anti-corruption legislation of the Republic of Uzbekistan and take an active part in the formation and implementation of anti-corruption standards and procedures.
  • The principle of involvement of personnel undergoing training. The personnel undergoing training are familiar with the main provisions of the Anti-Corruption Policy of the LLC, understand and adhere to this policy on a daily basis, contribute to the identification and suppression of facts, manifestations or signs of corruption.
  • The principle of proportionality of anti-corruption procedures to the risk of corruption. The development and implementation of measures is aimed at reducing the likelihood of the involvement of managers and employees in corrupt activities.
  • The principle of the effectiveness of anti-corruption procedures. The LLC strives to implement in its activities such anti-corruption measures that have an acceptable cost, ensure ease of implementation and bring significant results.
  • The principle of responsibility and inevitability of punishment. For LLC employees, regardless of the position held, length of service and other conditions, punishment for a committed corruption offense in connection with the performance of work duties is inevitable. The executive body of the LLC and the heads of the LLC departments bear personal responsibility for the implementation of the internal organizational anti-corruption policy.
  • The principle of openness. The company constantly informs clients, contractors, partners and the public about the anti-corruption measures being implemented, as well as about the manifestations of corruption that have taken place.
  • The principle of constant control and regular monitoring. The company carries out regular monitoring of the effectiveness of the implemented anti-corruption standards and procedures, as well as control over their implementation in accordance with the stipulated procedures.

2. The following persons are required to be guided by the Anti-Corruption Policy and comply with its requirements:

  • all employees of the LLC who are in employment relations with it, regardless of the position they hold and the functions they perform;
  • other individuals and (or) legal entities with whom the LLC enters into contractual relations, provides them with services or receives their services in the interests of its activities.

3. List of main anti-corruption measures.

On a regular (planned) basis:

  • Information support – signs, banners, information boards on combating corruption and explaining risk factors.
  • Audio, video recording.
  • Surveys of employees and personnel undergoing training at the LLC.
  • Collection of voluntary reports on instances of corruption (hotline).
  • Meetings, lectures, with the participation of law enforcement officials.

Events held on an unscheduled basis:

  • Participation of the management of the LLC in events to control knowledge and/or assimilation of material (exams, tests, checks).
  • Conducting anti-corruption raids, with the participation of representatives of law enforcement agencies, in order to identify facts of corruption.

4. All employees of the LLC are strictly prohibited from:

  • Attract or facilitate the attraction of legal entities or individuals related to these contractors and/or suppliers of work and services for work or provision of services in the interests of the LLC.
  • Conspire, attract or facilitate the attraction of legal entities or individuals for work or provision of services in the interests of the LLC, with the purpose of creating obviously favorable conditions for them and/or for personal enrichment.
  • Put pressure on employees of government agencies, ministries, departments and organizations, offer them bribes, gifts, and perform other actions that fall under the definition of corruption.
  • Put any pressure or influence on teachers or examiners of the LLC with the purpose of promoting the interests of any employees undergoing training at the LLC.
  • Initiate purchases or facilitate the purchase of goods and services in the interests of the LLC on terms that are obviously unfavorable for the LLC.
  • Facilitate access to the territory of persons who do not have the appropriate rights to stay in the LLC.

5. Teachers and examiners of the LLC are strictly prohibited from:

  • Use and/or demonstrate your acquaintances, personal and/or family ties in relation to employees undergoing training at OOO.
  • Show increased attention, create priority or discriminate against individual employees or groups undergoing training at OOO.
  • Put pressure on employees undergoing training at OOO with the purpose of extracting any benefit, receiving gifts, services, offers.
  • Use employees undergoing training at OOO for personal purposes, demand that they provide services, gifts.
  • Accept gifts, contributions, money, services in any amount from employees or groups undergoing training at OOO, regardless of whether this undermines the objectivity of the teacher’s actions, affects the grades he or she gives or not.

DISREGARDING THE PROHIBITIONS STATED IN PP. 4 AND 5 IS UNEQUIVOCALLY AND UNCONDITIONALLY CONSIDERED BY THE MANAGEMENT OF THE LLC AS A MANIFESTATION OF FACTS OF CORRUPTION.

6. All employees of the LLC are obliged to:

  • Refrain from behavior that may be interpreted by others as a willingness to commit or participate in committing a corruption offense in their personal interests, the interests of the LLC or third parties.
  • Immediately inform the management of the LLC of any suspicions regarding persons (whoever they may be) involved in corruption.
  • Take all available measures to prevent corruption, create a favorable image and a friendly environment in the organization.
  • Create conditions and in every way assist the administration of the LLC and law enforcement agencies in matters of preventing, detecting and suppressing corruption.
  • Carefully study, take note of and disseminate among employees anti-corruption information disseminated by the Administration of the LLC.

7. All employees of the LLC are guaranteed:

  • No prosecution of persons who identify and report manifestations of corruption or violations of the requirements of this document that may lead to corruption.
  • Impartial and comprehensive consideration and verification in accordance with the legislation of the Republic of Uzbekistan of any information received about violations of this document and/or manifestations of corruption.
  • Protection from slander, unfounded attacks, accusations, including counter-accusations.
  • Non-disclosure of information about the informant, if this does not contradict the legislation of the Republic of Uzbekistan.

8. Anti-corruption hotline:

  • In order to promptly receive information about manifestations of corruption in the LLC, a hotline telephone number is in operation.

  @aviatraining

To receive a timely response, the caller should not hide their phone number. Messages received from hidden numbers will be blocked.


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