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Donetsk national

Medical university

Anti-corruption program of

 Donetsk National Medical University named after M. Gorky


  1. General statements

1.1. This Anti-corruption Program (hereinafter - the Program) is developed in support of the state's anti-corruption strategy in order to ensure the observance of human and civil rights and freedoms, and observance of legal norms in the field of prevention and counteraction to corruption; eliminating the preconditions for its emergence through the introduction of preventive measures, strengthening the rule of law, equality of all before the law;

1.2. Anticorruption program of the Donetsk National Medical University named after. M. Gorky (further - the University) is developed on the basis of:

  • The Constitution of Ukraine of June 28, 1996;
  • Ukraine law on the Prevention of Corruption, 1700-VIІ from October 14, 2014;
  • Ukraine law "On the Principles of State Anti-Corruption Policy in Ukraine (Anti-Corruption Strategy) for 2014-2017" No. 1699-VII of October 14, 2014
  • Other anti-corruption by-laws.

1.3. The Donetsk National Medical University anti-corruption measures are aimed at:

- Prevention of corruption, including identifying and eliminating the causes of corruption (prevention of corruption);

- Detection of corruption offenses, disclosure and investigation of corruption offenses;

- Minimization and elimination of the consequences of corruption offenses.

  1. The range of persons affected by the anti-corruption program.

2.1. The anti-corruption program's action extends to the employees of the Donetsk National Medical University who are permanently or temporarily holding positions related to the implementation of organizational and administrative or administrative duties, or specially authorized persons for the performance of such duties, as well as other persons who are not officials or officials of any kind perform work or provide services in accordance with an agreement with the Donetsk National Medical University in cases stipulated by the Law of Ukraine "On Prevention of Corruption".

  1. The notions and terms used in the Anti-corruption program.

The anti-corruption program is a set of measures, rules and procedures aimed at identifying, preventing the occurrence and elimination of the consequences of corruption offenses at the Donetsk National Medical University.

Corrupt offense - an act that contains signs of corruption committed by a person specified in part one of Article 3 of the Law of Ukraine "On Prevention of Corruption", for which the law establishes criminal, disciplinary and / or civil liability.

  1. List of anti-corruption measures and rules in force at the University and the procedure for their implementation.

The Authorized Person on the Prevention and Counteraction of Corruption at the University (Rector's Order No.29 dated February 19, 2015) developed a system of measures to be implemented in order to counteract, eliminate the preconditions of occurrence and carry out appropriate activities to identify corruption risks at the Donetsk National Medical University.

4.1. The authorized person carries out constant control over the work of the contractual department, monitoring of business partners in order to prevent possible manifestations of corruption.

Providing the Authorized University with continuous monitoring of the state of compliance with the requirements of the current anti-corruption legislation, the causes and conditions that facilitate the commission of crimes and corruption offenses; definition of categories of employees and positions whose activities are associated with increased corruption risk. Implementation of the University's Economic Performance Audit for the Identification of Corruption Risks (assessment of the University's activities in terms of adverse consequences in the context of anti-corruption legislation). In order to identify the risks that the University faces as a result of violation of anti-corruption legislation, the Rector periodically initiates an audit of his economic activities. The audit results allow to identify areas of high risk and develop an effective plan of measures aimed at neutralizing the legal and commercial risks of the University. Risk assessment is a continuous process with constant communication between the Rector, the Commissioner and the University staff.

The University is making every effort to minimize the risks of business relations with counteragents that may be involved in corruption, which is why the contracting parties' compliance with corruption is being tested.

4.2. Organize in the structural units and student groups seminars on issues of prevention and counteraction to the manifestations of corruption.

4.3. Ensuring timely submission by the Donetsk National Medical University employees of property declarations, income, expenses and financial obligations for the current year.

4.4. The Commissioner is constantly analyzing the complaints and appeals of employees and citizens who perceive corruption violations. The obtained results should be considered at the administration, the academic council of the university, with relevant conclusions and recommendations.

4.5. Donetsk National Medical University employees are prohibited from:

  • using their official powers or their position and the related possibilities in order to obtain unlawful benefits for themselves or others, and also to use any state or communal property or funds in the private interests (Article 22 of the Law of Ukraine "On Prevention of Corruption");
  • directly or through other persons demanding, requesting, receiving gifts for themselves or close persons from legal entities or individuals in connection with the exercise by such persons of their official authority or if the person who grants is subordinate to such person;
  • directly or indirectly, in person or through third parties, making payments to simplify administrative, bureaucratic and other formalities in any form, in particular in the form of cash, value, services or other benefits, to any person or any person or organizations, including commercial organizations, bodies of government and self-government, civil servants, private companies and their representatives;
  • engaging or using intermediaries, partners, agents, joint ventures or other entities to commit any action that is contrary to the principles and requirements of this anti-corruption program or the rules of anti-corruption legislation.

4.6. Measures to be taken in case of receipt of an unlawful offer:

1) refuse the offer;

2) if possible, identify the person who have made the offer;

3) to bring witnesses, if possible, from among employees;

4) to inform in writing form about the proposal of the direct leader (if any) or the rector of the University, specially authorized subjects in the field of combating corruption.

If a person who is subject to restrictions on the use of the official position and for the receipt of gifts, found in his office or received unprofitable property or a gift, he must immediately, but not later than one business day, notify in writing this fact directly to the rector of the University or the Commissioner.

The identification of the property, which may be unlawful benefit, or a gift is an act signed by the person who found the wrongful benefit or gift, and its direct manager or the Commissioner.

Unlawful benefits, as well as gifts received or discovered, are kept at the Donetsk National Medical University until they are passed to specially authorized counter-corruption persons.

If an official has doubts about the possibility of obtaining a gift from her/him, she / he has the right to apply in writing for a consultation on this issue to the territorial agency of the National Agency, which provides an appropriate explanation.

  1. The standards of professional ethics of the University employees.

During the fulfillment of their duties, employees of the Donetsk National Medical University of all structural units should be guided by the following norms of professional ethics:

  • to comply strictly with the requirements of the Law of Ukraine "On Prevention of Corruption", job descriptions, the terms of the Collective Agreement, rules of internal regulations, local normative legal acts and generally accepted ethical norms of behavior, to be polite in relations with citizens, leaders, colleagues and subordinates;
  • continuously improve professional qualifications and improve the organization of their work;
  • to adhere to political neutrality, not to give any advantages or manifestations of favor to any of the political parties;
  • university officials shall not disclose and otherwise use confidential and other restricted information that has become known to them in connection with the performance of their official duties and professional duties, except in cases established by law;
  • when performing their duties, university employees are required to use (materially, efficiently and economically) the material and financial resources that are entrusted to them;
  • Officials of the University, regardless of private interests, should refrain from the execution of decisions or orders of the management if they are contrary to the law.


  1. Rights and duties of employees in connection with the prevention and counteraction of corruption in the activities of the University.

- Not to engage in corruption offenses related to the activities of the University;

- Refrain from behavior that can be interpreted by others as a willingness to commit or participate in committing a corruption offense related to the Donetsk National University's activities;

- To inform the Commissioner or the leadership immediately about incidents of the incitement to commit corruption offenses connected with the activities of the University;

-To take measures within the scope of its competence to terminate a corruption offense and immediately notify in writing of its commission a specially authorized subject in the field of combating corruption in case of revealing an offense of corrupt or corruption-related offense or receiving information about the commission of such an offense by Donetsk National Medical University employees;

- A person who has reported information about a corruption or corruption-related offense, depending on the economic effect of preventing or exposing it to the Donetsk National Medical University, may, be encouraged in accordance with the procedure established by the State Duma and the law according to the decision of the rector.

  1. Rights and duties of the Commissioner as an official responsible for the prevention of corruption

The Commissioner is a staff member of the Donetsk National Medical University or another official of the University, who is commissioned to perform the duties of the Commissioner. In the absence of a full-time position of the Commissioner, his rector may, temporarily (by the time of incorporation into the staff list of the Donetsk National Medical University this position and appointment of an employee to him), rely on another full-time employee (official) of the University, which is subject to appropriate changes to his job description.

The Commissioner may be dismissed from the office early on in the following cases:

1) Termination of an employment contract on the initiative of the Commissioner;

2) Termination of an employment contract on the initiative of the rector of the Donetsk National Medical University. A person who works as a Commissioner at the University referred to the second part of the  Article 62 of the Law of Ukraine "On Prevention of Corruption" may be dismissed subject to the consent of the National Agency;

3) The impossibility to carry out their powers for health according to the conclusion of the medical commission, which is created by a decision of the specially authorized central executive body, which implements the state policy in the field of health care;

4) The legal force of a court decision declaring him incapacitated or limiting his civil capacity, recognizing him as missing or declaring him dead;

5) The legal force of the conviction of the court regarding

The Commissioner is subordinate and accountable only to the Donetsk National Medical University rector.

The Commissioner has the following rights and obligations in performing his assigned tasks:

-Receive information from individuals and legal entities about violation of the requirements of the current legislation in the field of combating corruption, conduct on its own initiative an examination of possible violations of these requirements;

-To carry out inspections of the organization of work on prevention and detection of corruption in the departments of the Donetsk National Medical University;

-Implement monitoring and control over the implementation of legislation on ethical issues, preventing and resolving conflicts of interest in the activities of university staff;

-Receive written explanations from Donetsk National Medical University employees about circumstances that may indicate a violation of the rules of ethical conduct, prevention and settlement of conflicts of interest, other requirements and restrictions provided by the current legislation and anticorruption program;

-Initiate an official investigation; take measures to bring to justice the perpetrators of corruption or corruption-related offenses;

-Provide explanations, methodological and consultative assistance on issues of ethical behavior, preventing and resolving conflicts of interest, prevention and detection of corruption in the departments of the Donetsk National Medical University and its counterparts. The person concerned may personally apply for this purpose during the working hours to the Commissioner or send an appropriate written request, including by e-mail.

In case of revealing signs of corrupt or corruption-related offense or receipt of a notification of a corruption violation, the Commissioner initiates an official investigation. Obtained during the investigation materials Commissioner reports to the rector of the University, which is taking steps to bring the perpetrators to disciplinary action, and where signs of a criminal or administrative offense shall also inform the Commissioner in combating corruption.

  1. The conditions of confidentiality of informing the Commissioner of the University about the facts of incitement to commit a corruption offense or about other committed employees or persons of corrupt or corruption-related offenses. Protecting workers who provide assistance in preventing and combating corruption.

Person, including The Commissioner for illegal disclosure of confidential information may be brought to criminal, administrative or disciplinary responsibility for its disclosure in accordance with the requirements of the current legislation.

The information received to the Commissioner, the rector and / or vice-chancellors of the employee's educational process of the University or any other person about the facts of incitement to commit a corruption offense committed by agents or anti-corruption program or Donetsk National Medical University lecturer corruption or corruption-related offenses is confidential, access to which may be restricted in accordance with the procedure established by law.

  1. Procedures for the protection of employees (disclosers) who reported information about corruption or corruption-related offenses.

Persons providing assistance in preventing and combating corruption are protected by the state. In the event of a threat to the life, housing, health and property of persons providing assistance in preventing and combating corruption, or their relatives, in connection with the reported violation of the requirements of the Law "On the Prevention of Corruption" and this anti-corruption programs, law enforcement bodies, legal, organizational and technical measures and other measures aimed at protection against unlawful encroachment, which are provided for in the Law of Ukraine "On ensuring the safety of persons involved in criminal proceedings", may be applied to them.

DEVELOPED:                                                      Chief jur. Department A. Yu. Tsarytsenko

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