The mission of the “Institute of Liberal Politics” is the strengthening of liberal democratic institutions and rule of law, through evidence-based policymaking, non-formal education, alternative expertise, and assisting vulnerable groups, state and local self-governance institutions, mass media institutions and other beneficiaries, establishing a dialogue between the state and society.

The “Institute of Liberal Politics” non-governmental organization (NGO) was established in 2018 in Yerevan, but the geography includes the whole area of Armenia and Artsakh.

Since its establishment Institute has implemented various projects aimed at strengthening liberal democratic institutions and rule of law: combating disinformation and hate speech, raising media literacy, and discussing prospects of Armenia-EU relations, democratic reforms in Armenia, development of local self-governance, raising the participation of women and improving their skills, improving entrepreneurial skills, etc.

The Institute is an independent think tank, which conducts various research and expertise, develops evidence-based strategies aimed at the improvement of specific fields and bringing real change.

An important component of the work is non-formal education aimed at enriching knowledge, filling the gaps of formal education, talent seeking and promoting, raising the consciousness of society.

Since its establishment, the Institute implements the “School of Liberal Politics” project, which is a non-formal educational programme for talented youth, interested in liberalism, human rights and politics.

The School has more than 170 alumni who stay in touch through participation and alumni network.

The Institute works in the directions represented below. The directions are listed in the Charter of the Organization:

• To organize educational workshops, seminars, trainings, conferences, which will be aimed at the development and strengthening of democracy and liberalism in Armenia,
• To conduct stuides, analyzes and surveys.
• To repare and publish informational and promotional materials, clips and films that will have educational and awareness-raising goals.
• To cooperate with local and international educational institutions, non-governmental organizations and foundations.
• To collaborate with the media to increase public awareness on democracy, liberalism and human rights.
• To cooperate with state and local self-government bodies in educational and research spheres.
• To raise the legal awareness of the youth through non-formal education and to support the formation of a new political culture.
• To participate in the development and implementation of national and international political programs.
• To establish links with regional and international political and educational institutions, promoting the integration of Armenian political organizations into those structures.
• To keep contact with similar organizations and international networks in and outside of Armenia for the purpose of experience exchange and implementation of joint programs.

Table of Contents

I. General Provisions

II. Purpose

III. Basic Rules and Variations

3-1 Rules specific to Public Officials

3-2 Gifts and Invitations

3-3 Gifts and Donations to Charities or Political Organizations

3-4 Sponsorship and Patronage

3-5 Facilitation Payments

3-6 Third-Party Due Diligence (Suppliers, Service Providers, and Partners) 

3-7 Conflict of Interest 

3-8 Accounting Records and Internal Audits 

IV. Procedural aspects 

4-1 Training and Awareness 

4-2 Reporting of Practices non-compliant with Code and Whistleblower Protection 

4-3 Punishments in the event of Violation of the Present Code 

4-4 Implementation:  Responsibility and Surveillance 

4-5 Data Protection & Confidentiality 

V. Rules for Publication, Coming into Force and Amendments of the Anti-corruption Code of Conduct 

5-1 Publicity 

5-2 Coming into force 

5-3 Amendments 

Adopted by the Board of “Institute of Liberal Politics” Non-governmental organization on July 20, 2022.

I. General Provisions 

Purpose and Scope

This Anti-Corruption Code of the Institute of Liberal Politics (hereinafter referred to as “ILP”) establishes principles, rules, and mechanisms to prevent, detect, and respond to corruption-related risks within the organization. This policy applies to all employees, members, contractors, and partners involved in ILP’s activities.

Legal Framework

This code is developed in accordance with the Constitution of the Republic of Armenia, the Law on Public Organizations, the Law on Combating Corruption, the Criminal Code of Armenia, and other relevant legal acts and international anti-corruption conventions, such as United Nations Convention against Corruption (UNCAC) and the OECD Anti-Bribery Convention, ratified by Armenia. 

Principles

ILP upholds the following key principles in its anti-corruption efforts:

• Zero Tolerance – ILP strictly prohibits any form of corruption, including bribery, fraud, nepotism, and conflict of interest.

• Transparency – All financial transactions, decision-making processes, and activities must be conducted openly and be subject to oversight.

• Accountability – Employees and partners must take responsibility for ethical conduct and report any suspected corruption cases.

• Impartiality – Decisions must be made based on merit, free from favoritism or personal interest.

• Compliance with the Law – ILP and its members must adhere to all applicable anti-corruption laws and regulations in Armenia.

Definitions

* Corruption is conduct, by which a person (public official or private person) makes, demands or accepts, directly or through an intermediary, an offer or promise, gifts or any advantages with a view to accomplishing, delaying or not accomplishing an act entering directly or indirectly into the scope of his/her functions in order to obtain or conserve a commercial or financial advantage, or influence a decision. 

There are two forms of corruption:

• Active corruption occurs when a person initiates an act of corruption by offering or providing an undue advantage.

• Passive corruption happens when an individual receives or solicits an undue advantage in exchange for a decision or action.

Corruption can assume several forms under the guise of commercial or current social practices; In particular, it can include invitations, gifts, sponsorships, donations, etc. 

 *Influence peddling denotes the act of a person cashing in on his/her real or supposed quality or influence to impact a decision that will be made by a third party. 

This involves three stakeholders:

• The beneficiary (the person who provides advantages or donations), 

• The intermediary (the person who uses the credit he/she possesses because of his/her position) 

• The target person, who has the decision-making power (public authority or administration, magistrate, expert, etc.). 

*Bribery – The offering, giving, receiving, or soliciting of something of value to influence an official decision.

*Conflict of Interest – A situation where personal interests interfere with professional duties and responsibilities.

*Fraud – Deliberate deception to secure unfair or unlawful financial or personal gain.

Applicability

This policy applies to all individuals associated with ILP, including but not limited to employees, board members, consultants, volunteers, and partner organizations. Any violations may result in disciplinary actions, including termination of contracts and legal consequences in accordance with Armenian law.

II. Purpose  

The purpose of this Code is to establish clear guidelines for preventing, detecting, and addressing corrupt practices and influence peddling within the ILP. This Code defines the types of conduct that are strictly prohibited as they may constitute acts of corruption, conflicts of interest, or unethical behavior that undermine the integrity and mission of ILP.

This Code complements, rather than replaces, the principles, rules, and obligations established by applicable laws, internal regulations, and organizational procedures in force within ILP. It serves as a fundamental framework for ethical conduct and compliance, reinforcing ILP’s commitment to transparency, integrity, and accountability in all its activities.

Each member of ILP is individually responsible for maintaining the highest standards of ethical conduct and ensuring full compliance with this Code. It is their duty to prevent, identify, and report any corrupt practices or unethical behavior that may arise within the organization.

To ensure proper implementation, any questions regarding the interpretation or application of this Code should be referred to the relevant supervisory authority within ILP. The organization is committed to fostering an open environment where concerns related to corruption and ethical misconduct can be raised without fear of retaliation.

Recognizing that no single document can address all potential corruption risks, ILP expects all individuals to exercise sound judgment, professional discretion, and common sense when dealing with ethical dilemmas. In cases where uncertainty arises, individuals should seek guidance rather than act in a manner that could compromise the organization’s integrity.

By adopting and strictly adhering to this Code, ILP reinforces its dedication to upholding the highest ethical standards, ensuring that its operations remain free from corruption and misconduct, and preserving the trust of its stakeholders, partners, and the broader community. 

III. Basic Rules and Variations 

Principle and rules 

ILP is committed to upholding the highest standards of integrity and transparency in all its activities. Staff members, including managers, employees, volunteers, and external partners, must not engage in any form of corruption, including bribery, embezzlement, influence peddling, or any other illicit practice.

In adherence to Armenian anti-corruption legislation, including the Convention against Corruption, Criminal Law Convention on Corruption, Civil Law Convention on Corruption, Criminal Code of the Republic of Armenia, the Law on Public Service, the Law on the Commission for the Prevention of Corruption, and the Law on Whistleblower Protection, all ILP representatives must act ethically and in full compliance with applicable regulations.

To ensure compliance, all staff members must ask themselves the following questions when making decisions:

• Are the laws and regulations being respected?

• Does the action comply with ILP’s internal policies and ethical standards?

• Is the decision free from any personal interest or conflict of interest?

• Would my decision withstand public scrutiny if disclosed?

To encourage ethical decision-making, ILP has established confidential reporting mechanisms where staff members can seek guidance or report suspected violations without fear of retaliation.

Staff members shall not commit acts of corruption and shall not use intermediaries, such as agents, consultants, advisers, distributors or any other commercial partner with the aim of committing such acts. 

If a person is confronted with a proposal, he/she must ask: 

• Are the laws and regulations respected? 

• Does it comply with the Code and the company’s interest? 

• Is it free from any personal interest? 

• Will I be compromised, if my decision were to be communicated? 

Each organization referring to the Code has established a procedure such that each employee can express, in total confidentiality, his/her doubts and uncertainties, if he/she is faced with a choice involving ethics or business conduct. 

3-1 Rules specific to Public Officials 

Definitions

A person holding a public service position or, in cases and in accordance with the procedure established by law, being in the relevant reserve of state or community service personnel is considered a public servant. This definition aligns with the Law of the Republic of Armenia on Public Service (Article 5, part 4), and other relevant legal provisions governing public service ethics.

Principles and Rules

Corruption involving public officials is subject to severe legal penalties under Armenian law. For instance, under the Criminal Code (Article 435-437), bribery of a public official can result in imprisonment, substantial fines, and legal sanctions against both the individual and the organization involved.

To prevent such violations, ILP strictly enforces the following rules when interacting with public officials:

• All engagements must comply with the relevant laws and regulations governing public officials.

• Any advantage, benefit, or gift provided to a public official must be fully transparent and pre-approved by ILP management.

• No employee or representative of ILP may attempt to influence a public official’s decision through improper means, including financial or material incentives.

If a staff member is uncertain about the legality of an interaction with a public official, they must seek prior guidance from ILP.

3-2 Gifts and Invitations 

Definitions

Gifts and invitations can resemble or be perceived as acts of active or passive corruption, so due care and attention shall be given in relation to gifts, signs of courtesy and hospitality (received or given), invitations to entertainments that contribute to establishing good relations, but can be considered to be ways of influencing a decision, or favoring a company or person. 

Principles and Rules

• Gifts and hospitality must never be offered or accepted if they could be perceived as an attempt to influence a decision.

• Any gift, regardless of value, must be transparent, reasonable, and culturally appropriate.

• Hospitality expenses must be pre-approved and properly documented.

Under Armenian anti-corruption laws, improper gifts or benefits to public officials or private entities may constitute bribery (Criminal Code, Article 435-437). 

3-3 Gifts and Donations to Charities or Political Organizations

Definitions

Gifts and donations include financial contributions or in-kind support given to charitable, educational, environmental, or humanitarian initiatives. Political contributions refer to any financial or non-monetary support provided to political parties, campaigns, or candidates.

Principles and Rules

• Donations to charitable organizations must be approved by ILP Board and free of any expectation of influence or benefit.

• ILP does not make contributions to political organizations, parties, or candidates to maintain neutrality and avoid conflicts of interest.

• All donations must be properly documented and comply with Armenian regulations on financial transparency.

3-4 Sponsorship and Patronage

Definitions

Sponsorship and patronage involve financial or material support provided to social, cultural, or sporting initiatives to promote ILP’s values and mission.

Principles and Rules

• Sponsorship agreements must be transparent and properly documented.

• ILP shall not provide sponsorships or patronage in exchange for undue influence or business advantages.

• All sponsorship activities must be in compliance with Armenian legislation on corporate social responsibility and anti-corruption.

3-5 Facilitation Payments

Definition

Facilitation payments are unofficial payments made to expedite administrative procedures, such as obtaining permits, processing visas, or clearing customs.

Principles and Rules

• ILP strictly prohibits facilitation payments in all forms, except in cases where the personal safety of a staff member is at immediate risk.

• Employees must report any request for a facilitation payment to ILP’s compliance officer.

• Violation of this policy may lead to disciplinary action and legal consequences under Armenian law.

3-6 Third-Party Due Diligence (Suppliers, Service Providers, and Partners)

Definition

Third parties include external entities that ILP collaborates with, such as suppliers, contractors, consultants, and partner organizations.

Principles and Rules

• ILP conducts thorough due diligence on all third-party partners to assess potential corruption risks.

• Contracts must include anti-corruption clauses ensuring compliance with Armenian and international laws.

• ILP reserves the right to terminate any partnership with entities found engaging in corrupt practices.

3-7 Conflict of Interest

Definition

A conflict of interest arises when an ILP staff member’s personal interests interfere with their professional duties, potentially influencing decision-making.

Principles and Rules

• Staff members must disclose any actual or potential conflicts of interest to ILP management.

• Decisions must be made solely in the best interest of ILP, without personal bias or external influence.

• Failure to disclose a conflict of interest may result in disciplinary action.

Under the Law on Public Service (Article 24), A senior official may not take any action or make a decision regarding a conflict-of-interest issue until he or she has received written consent from a superior. 

3-8 Accounting Records and Internal Audits

Definition

Financial records and internal audits ensure transparency, accountability, and compliance with financial regulations.

Principles and Rules

• All financial transactions must be accurately recorded and regularly audited.

• Accounting records must reflect legitimate and lawful activities, without concealment of corruption-related expenses.

• Internal and external auditors must remain vigilant in detecting irregularities that may indicate corruption or financial misconduct.

Under Armenian financial and anti-corruption legislation, improper financial documentation can result in legal liability, including penalties under the Criminal Code (Article 457).

IV. Procedural aspects

4-1 Training and Awareness 

ILP management, including managerial and non-managerial personnel most exposed to risks of corruption and influence peddling, shall receive training on these issues, which they are required to attend.

Staff members are required to read and be aware of the present Code and shall be informed about the fight against corruption and influence peddling by their managers.

4-2 Reporting of Practices non-compliant with Code and Whistleblower Protection 

Each staff member may raise doubts and questions with their manager and/or designated person in compliance with the procedure defined by ILP, if:

• They face a risk of corruption or influence peddling.

• They believe, in good faith, that a violation of the Code has been, is being, or will be committed.

• They discover that someone is facing retaliation for reporting a practice in good faith.

Any staff member who reports, in good faith and selflessly (i.e., sincerely convinced that their declaration is accurate), a violation or risk of violation of the Code to their management or designated person shall be protected against all forms of retaliation.

Their identity and the facts shall be treated confidentially in compliance with Armenian laws and regulations.

Additionally, an error made in good faith shall not lead to disciplinary measures, while malicious reports intended to harm or deceive will be subject to punishment.

Whistleblowers shall be protected from retaliation, including dismissal, harassment, or discrimination. Any attempt to retaliate against a whistleblower will result in disciplinary action, up to and including termination of employment.

4-3 Punishments in the event of Violation of the Present Code 

Each staff member is personally accountable for non-compliance with the rules, which may expose them to penalties, including criminal liability.

ILP undertakes to:

• Take into account all reports of violations.

• Investigate all warnings thoroughly.

• Assess the facts objectively and impartially.

• Take corrective measures and impose adequate disciplinary sanctions.

Any breach of the provisions of the present Code will be subject to disciplinary penalties outlined in ILP’s Internal Regulations.

A manager or staff member of ILP, or its foreign affiliates, who breaches the provisions of the present Code, may face disciplinary penalties as stipulated by Armenian legislation on contractual relations.

To ensure accountability, violations of this Code will be reviewed by a Board, which will determine appropriate disciplinary actions. Depending on the severity of the violation, consequences may include:

• Formal warnings for minor infractions.

• Mandatory ethics training for repeated or moderate violations.

• Termination of employment or legal action for serious violations, including corruption or bribery.

4-4 Implementation:  Responsibility and Surveillance 

Each staff member is responsible for implementing the Code within the scope of their duties.

ILP shall perform periodic checks to verify compliance with the Code.

The governing bodies of ILP shall regularly review monitoring of Code implementation and follow-up actions to any warnings.

4-5 Data Protection & Confidentiality

ILP is committed to safeguarding confidential information and personal data. Staff members must adhere to all applicable data protection regulations (e.g., Armenian national privacy laws) to prevent unauthorized access, disclosure, or misuse of sensitive information.

V. Rules for Publication, Coming into Force and Amendments of the Anti-corruption Code of Conduct 

5-1 Publicity 

A copy of the Anti-corruption Code of Conduct shall be provided to each new recruit at ILP. In any event, the Anti-corruption Code of Conduct shall be prominently displayed on the premises of ILP and all affiliated organizations, as well as on ILP’s official web site.

5-2 Coming into force 

The Anti-corruption Code of Conduct shall come into force one month after fulfilling the required publication and filing formalities with the Armenian authorities. The Code shall be considered officially active starting from the date of its final publication. 

5-3 Amendments 

Amendments and additions to the Anti-corruption Code of Conduct shall be subject to the same communication, publication, and filing procedures as the original Code.

Any clause that becomes inconsistent with legal, regulatory, or conventional provisions due to changes in Armenian laws or regulations shall be automatically null and void.

ILP shall ensure that any modifications comply with Armenian legislation and are promptly communicated to all relevant parties.

In the event of any doubt about appropriate conduct, each member, employee, and volunteer of ILP shall base their actions on the guidance and advice provided through ILP’s internal support systems, including the internal warning system.