Miller Law Firm recognizes the importance of fighting corruption and maintaining high standards of ethics and compliance.
This policy is aimed at ensuring transparency, responsibility and integrity in all aspects of our business.
We strive not only to comply with legal requirements, but also to be a role model for the legal market through our actions.
II. Policy goals and objectives
Preventing corruption: Provide all employees with clear rules and instructions on how to avoid corrupt practices.
Transparency: Ensure that information about the company’s activities is open and accessible to all stakeholders.
Responsibility: Increase the level of personal responsibility of each employee for compliance with ethical standards.
Training and information: Regularly conduct trainings and information sessions for employees on anti-corruption compliance.
III. Policy principles
Zero tolerance for corruption: Miller has a zero-tolerance policy for all forms of corruption and bribery.
Compliance with the law: All employees are required to comply with the anti-corruption laws of Ukraine and international standards.
Ethical behavior: All employees of the company must adhere to high ethical standards in their work and relationships with clients, partners and government agencies.
Conflict of interest: Avoiding and disclosing any conflicts of interest that may affect the objectivity and impartiality of decision-making.
IV. Practical measures
1. 1. Training and briefings
Regular trainings: Training sessions are held quarterly for all employees, including new hires. Training includes simulations, practical exercises and lectures on anti-corruption policy and ethics.
Information materials: Providing employees with printed and electronic materials with the main provisions of the anti-corruption policy, examples of corruption and ways to prevent them.
Raising awareness: Organize regular webinars and seminars with experts in the field of anti-corruption compliance.
2. Channel for reporting corruption
Confidential communication channel: An email channel for anonymous reporting of corrupt practices. All reports are thoroughly reviewed by a specially appointed company committee.
Whistleblower Protection Policy: Guarantee of protection for employees who report corruption so that no whistleblower is subjected to harassment or any form of discrimination.
Procedures for handling reports: Establish clear procedures for handling reports, including timeframes for review, collection of information, and feedback to whistleblowers.
3. Internal investigations
Ethics and Compliance Committee: Establishment of a special group to conduct internal investigations of possible corruption, consisting of experienced employees, management representatives and, if necessary, independent external experts.
Internal investigation procedure: Establishing clear procedures, including gathering evidence, conducting interviews, reviewing employee emails, analyzing documents, and writing a report.
Documentation of the process: All stages of the investigation are documented, including findings and recommendations for further action.
4. Audit and monitoring
Regular audits: Conducting annual internal and, if necessary, external audits to verify that processes and procedures comply with anti-corruption standards.
Risk monitoring: Identification and ongoing monitoring of possible corruption risks in the company’s activities. Implementation of measures to minimize them.
Reporting to management: Regular reporting of audit findings and corrective actions to management.
V. Responsibility
1. 1. Management’s responsibility
Leadership: Leadership is fully responsible for implementing and adhering to the policy and sets an example of ethical behavior.
Support: Provides the necessary resources (financial and human) to implement anti-corruption measures.
Reporting and accountability: Regularly reports to the board of partners on policy implementation.
2. Individual responsibility
Awareness: Every employee is required to know and comply with the policy.
Reporting: Employees report any suspected corruption or policy violations immediately through established channels.
Ethical culture: Everyone contributes to the formation of an ethical culture in the company.
VI. Violations and sanctions
1. Investigation of violations
Internal investigation procedures: All suspicions are investigated by the Ethics and Compliance Committee in accordance with established procedures.
Cooperation: Employees are required to cooperate by providing the necessary information and documents.
Confidentiality: Investigations are conducted confidentially to protect the rights of all involved.
2. Sanctions.
Disciplinary measures: In case of violations, disciplinary measures, including dismissal, fines or other administrative sanctions, will be applied.
Reporting to law enforcement agencies: In case of serious violations, the information may be reported to the relevant authorities.
Compensation for losses: If the violation has caused material damage to the company, the perpetrators are obliged to compensate for it.
