The students of the Anti-Corruption School for Young Leaders in the scope of the “Armenia: Promoting Anti-Corruption Conduct and Reforms” project discussed the Anti-Corruption Compliance Program (ACC) with Ms Lusine Nalbandyan, the Lawyer/Expert of the Armenian Lawyers’ Association.

The expert first presented the common models of liability of legal entities, presenting the experience of Anglo-Saxon and continental law countries. Further she spoke about Armenia’s international commitments, within the framework of which Armenia is required to provide for the institute of legal responsibility of a legal entity. Emphasize was made on the necessity of introducing ACCP in Armenia.

She presented facts about the corruption risks in the business sphere in Armenia, in particular the high risk of corruption in the investing countries in Armenia. She also touched upon the individual and global benefits of economic entities, in case they implement the ACCP with all its components. According to her, the private sector needs the introduction of the ACCP. It will help the company avoid criminal liability, reduce business costs, attract new investments, enhance the business reputation of the company, improve the business environment in Armenia and prevent the emerging of corruption risks, which will gradually reduce corruption in the business sector.

An important principle of the ACCP is the involvement of the company head in the process,accountability, transparency of the process, efficiency, and control and engagement ofemployees. The expert noted in her speech that it is important that the management shall show commitment during the implementation of ACCP, including corporate governance, ethics, and business turnover. Management should be committed to involve employees in the process by being an example for them.

“Risk assessment is also important. Weaknesses should be found, to determine the degree of
probability of corruption, and to give special guidance on the possibilities of the origin ofcorruption. It is necessary to implement a risk management plan, evaluate and periodically
review it. ACCP is not a stagnant system; it involves constant improvement and monitoring. We cannot invest ACCP only in the private sector and succeed in fighting corruption; it should also work within the public service,” Lusine Nalbandyan said.