Compliance and internal investigations
Building the compliance function of a company and investigating breaches inside it: anti-corruption programmes under the Law on the Prevention of Corruption and the FCPA, UK Bribery Act and ISO 37001 standards, internal policies and whistleblowing channels, counterparty checks (KYC), investigations of fraud and abuse, staff training and support in dealings with NABU, the NACP and the State Bureau of Investigation.
Anti-corruption compliance programmes
Developing and implementing anti-corruption programmes in line with the Law on the Prevention of Corruption and international standards (FCPA, UK Bribery Act, ISO 37001). Assessing corruption risks and appointing authorised officers.
A modern anti-corruption programme has to be a risk management tool, not a formal set of internal documents.
PROCTOR designs compliance systems that are built into the real business processes of the company. We analyse the organisational structure of the business, the procedures for taking management decisions, procurement, sales, dealings with state authorities, the internal control system and corporate governance.
Every programme is adapted to the specifics of the company's operations, to international compliance standards and to the requirements of Ukrainian legislation.
Our aim is to create a system that genuinely reduces the risk of criminal prosecution of officers and protects the business during inspections and internal investigations.
Internal corporate investigations
Investigating fraud, misappropriation, conflicts of interest and abuse inside the company: gathering and recording evidence, interviewing employees, legal assessment. The results are fit for use in court and in criminal proceedings.
Compliance audit of counterparties (KYC)
Checking business partners before contracts are signed: beneficiaries, sanctions lists, litigation history, signs of a sham business. Protecting the company from the tax and criminal risks of working with problem counterparties.
Policies and procedures
Drafting internal documents: an anti-corruption policy, a conflict of interest policy, a policy on gifts and hospitality expenses, and a policy on dealings with state authorities.
Whistleblowing channels
Building secure channels for reporting breaches in line with the requirements of whistleblower legislation. Procedures for handling reports and protecting whistleblowers from retaliation.
Training for staff
Training employees and management: anti-corruption requirements, behaviour during a search, communication with law enforcement officers, sanctions compliance. Formats range from webinars to practical simulations.
Support in dealings with NABU, the NACP and the State Bureau of Investigation
Legal support for companies and officers during inspections by the NACP and during requests and investigative actions by the anti-corruption authorities. Protecting interests in cases on corruption offences.
How we build the compliance function
From a diagnosis of the existing processes to a working programme, trained people and a live reporting channel.
01
Risk diagnosis
We study the structure of the company, its markets, its counterparties and how approvals actually work. We draw a map of corruption, sanctions and fraud risk with likelihoods.
02
Drafting the policies
We prepare the anti-corruption programme, rules on gifts and conflicts of interest and the counterparty check procedure. The documents are written for the processes of this company.
03
Whistleblowing channel
We launch a reporting line with guarantees of confidentiality and a procedure for handling reports. It is set out who receives a signal and in what time a decision is taken.
04
Training for staff
We train managers, sales and procurement on examples from their own industry. After the training we check that people recognise a risky situation in their own work.
05
Internal investigation
When a report comes in we verify the facts: analysis of documents, interviews with employees, work with data. The outcome is a report with findings and recommended consequences.
06
Review of the programme
Periodically we check how the programme performs: counterparty checks, reports on the line, results of investigations. The policies are updated for new risks.
Formats of compliance work
The scope depends on whether the company is starting from nothing, or already has a programme and needs support.
Audit of the compliance function
An assessment of the existing policies and procedures and of how they are followed in practice. The result is a report listing gaps, risks and the order in which to close them.
Implementing the programme
Drafting and launching the anti-corruption programme: policies, the counterparty check procedure, the reporting channel, staff training and the appointment of a responsible officer.
Standing compliance support
Our lawyers run the function permanently: counterparty checks, handling of reports, internal investigations, updates to the policies and support in dealings with the NACP.
