09.10.2018

The Center for International Private Enterprise (CIPE)

On 1 October, the “Armenia: Promoting Anti-Corruption Conduct and Reform” project, which is implemented by the Center for International Private Enterprise (CIPE), the Armenian Lawyers Association, the Corporate Governance Center and the Yerevan Chamber of Commerce and Industry was launched.

The objective of “Armenia: Promoting Anti-Corruption Conduct and Reform” project is to introduce anti-corruption programs in Armenia’s businesses, which will contribute to the insemination of the values of corporate governance and ethics in Armenia.

Within the framework of the project, it is also envisaged to work closely with small and medium enterprises to raise awareness about the Anti-Corruption Compliance Program.

On October 3-5, Yerevan hosted training for trainers on the implementation of the Anti-Corruption Compliance Program, proper control over it, including ensuring independence, the need for periodic assessment of existing risks and the need for internal procedures.

On the first day of the training, Ms Natalia Otel Belan, Deputy Regional Director of CIPE for Europe and Eurasia, presented the importance of the program, its objective and the stages the project will precede.

“We will focus on four main points: the first is the sharing of knowledge, and this three-day training is for the trainers. Then we must be convinced that you as individuals can work in your organizations. The next big stage will be to provide support to the business sector; it is about the possibility of creating a dialogue between the public and the private sector. And this is especially important now, as the government’s focus is on the scope of anti-corruption programs; this is the right time for all organizations to build a constructive dialogue with the government. The project, which will finish in about 12 months, aims to gather many ideas and based on them build a basis for partnership,” Natalia Otel Belan said. She also noted that even if the government will change in Armenia, and the business sector will manage to adopt Anti-Corruption Compliance Programs before that happen, the program will remain by all means, as there will be already adopted and approved norms.

Ms Liza Lenz Jedwab, Assistant Program Officer for Eurasia spoke about the objective of the project, the activities that will be carried out with organizations and how to make a questionnaire, receive answers from a large number of business auditoriums. “Since this topic is new, we have to figure out the purpose of the questionnaire to understand what business we are dealing with, the extent to which the business sector is aware of this. The second objective is to establish direct contact with the organizations that are not informed, inform them, about the existence of such thing and that they can participate,” she said.

During the days of the training, Ms Yuliya Glubokaya, Deputy Compliance Officer of VimpelCom Company, introduced the Anti-Corruption Compliance Program to the participants. She presented the self assessment tool on ACC, successful experience, as well as Armenian and international contexr for AAC. She also spoke about the independence of the compliance function. The discussion also covered anti-corruption policy; conflict of interest policies; as well as policy on giftsand hospitality; policy on commercial sponsorships, social investments and charitable contributions.

“We attach great importance to the Anti-Corruption Compliance Program, because businesses will only benefit from the implementation of the mentioned program, because there is already a draft Criminal Code of Armenia, which already provides for criminal liability for legal entities. In parallel, it is envisaged that this liability will be avoided, if legal persons have taken appropriate measures and this is the very basis for inclusion of the Anti-Corruption Compliance Program. That is, if a legal entity can prove that it has done everything and has taken all possible measures to avoid corruption conduct of its employees, then  the company will not be prosecuted for corruption,” Ms Mariam Zadoyan, the Component Manager of the Armenian Lawyers Association of the “Armenia: Promoting Anti-Corruption Conduct and Reform” project said.

According to her, this is also an opportunity to develop business and attract investments from a number of foreign companies in Armenia, as it is important for such companies that the organizations have an Anti-Corruption Compliance Program.

Ms Narine Melikyan, President of Corporate Governance Center, Component Manager of the Corporate Governance Center of the mentioned project said that the program already has some background for the organization and that they had thought about anti-corruption compliance 3 years ago: however in the opinion of the organization the that time was not appropriate for implementation of their idea. Then they translated and presented the CIPE Guide on Anti-Corruption Compliance for Small and Medium Enterprises. It turned out that the events of late April in Armenia showed  that the topic is very urgent and if some of the discoveries relate to large companies, they seem financially able to take care of their anti-corruption compliance. And here, the small and medium-sized enterprises remain out of the game,” she said. Narine Melikyan also noted that it is important not to say that the company will adopt the anti-corruption compliance program, but that it will apply and adhere to the commitment it has undertaken.

Vladimir Amiryan, the Adviser to the President of the Chamber of Commerce and Industry of Yerevan and the Coordinator of the Business Advocacy Network is the Head of the International Cooperation Department of the Chamber of Commerce and Industry of the Republic of Armenia, and the Component Manager of the Chamber of Commerce and Industry of Yerevan of the mentioned project also noted that it is possible this may be accepted skeptically in Armenia. “Several years ago there was some skepticism in me because there is a stereotype that everything depends on the state system, that is, if the state does not want, business will not be involved in corruption, and everything will be OK, but I think it is a two-sided process. We always talk about corruption in the public sector and we always forget about the risks offered the private sector or about the potential corruption risks,” he said. According to Vladimir Amiryan, it is necessary to start active work so that the project is targeted and effective.