About Us
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.
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.
CODE OF ETHICS
“INSTITUTE OF LIBERAL POLITICS”
Non-Governmental Organization
Table of Contents
VII. Transparency and Disclosure. 5
XIII. Whistleblower Protection.. 7
XIV. Public Communications & Social Media Use. 7
Annex
1: Examples of Conflict-of-Interest Situations. 8
Adopted by the Board of “Institute of Liberal Politics” Non-governmental organization on July 20, 2022.
I. General provisions
- The Code of Ethics (hereinafter referred to as “Code”) of “Institute of Liberal Politics” (hereinafter referred to as “Organization”) is a fundamental document that defines the values and principles of the activities of the Organization, the rules of conduct for the members, employees and volunteers, management, issues related to applying liability measures for violations thereof, as well as other issues associated with the relations arising from this Code.
- The purpose of the Code is to orientate the members, employees, and volunteers of the Organization into being guided by the fundamental values and principles adopted by the Organization and to act with high standards of honesty and responsibility.
- To ensure compliance with this Code of Ethics, the Organization establishes the following enforcement mechanisms:
A three-step disciplinary process, including:
- -Written Warning – Issued for minor infractions.
- -Corrective Action Plan – Required for repeated or serious ethical breaches.
- -Dismissal or Contract Termination – Applied in cases of severe violations.
II. Personal and Professional Integrity
All staff, board members, members and volunteers of the “Institute of Liberal Politics” Non-governmental organization act with honesty, integrity and transparency in all their dealings with each other both within the organization and as representatives of the organization. The organization promotes a working environment that values respect, fairness, integrity, equal treatment and collaboration.
The organization is not to be part of, or controlled by, government or an intergovernmental agency.
The organization shall maintain independence and not be rigidly aligned or affiliated with any political party, although it may share a common political or legislative cause within the limit of its mission, stated objectives and legal structure.
The Organization operates with full independence from any government, political party, or intergovernmental agency. While it may advocate for policies aligned with its mission, it does not serve as a tool for government agendas. No external political entity shall have direct influence over the Organization’s decisions, programs, or priorities.
III. Support of Mission
The organization has a clearly stated mission and purpose, approved in the Charter of the organization, in pursuit of the public good. All of its programs support that mission and all who work for or on behalf of the organization understand and are loyal to that mission and purpose. The mission is responsive to the constituency and communities served by the organization and are of value to the society at large.
IV. Governance and Accountability
The organization has an active board that is responsible for setting the mission and strategic direction of the organization and oversight of the finances, operations, and policies of the organization. The board of directors through adopted policy:
- Exercises reasonable care, good faith, loyalty and due diligence in organizational affairs;
- Has a conflict of interest provision that ensures that any conflicts of interest or the appearance thereof are avoided or appropriately managed for the protection and benefit of the organization;
- Ensures that the organization conducts all transactions and dealings with integrity and honesty;
- Ensures that the organization promotes working relationships with board members, staff, volunteers, and program beneficiaries that are based on mutual respect, fairness, and openness;
- Ensures that the organization is fair and inclusive in its hiring and promotion policies and practices for all board, staff and volunteer positions;
- Ensures that the resources of the organization are responsibly and prudently managed; and,
- Ensures that the organization has the capacity to carry out its programs effectively.
V. Truthfulness and Legality
The organization is knowledgeable of and complies with all applicable laws, regulations and international conventions.
- The NGO gives out accurate information, whether regarding itself and its projects, or regarding any individual, organization, project, or legislation it opposes or is discussing.
- The NGO does not engage in any activities that are unlawful under the laws of the nation in which it is organized or works, and must be strongly opposed to, and not be a willing partner to, corruption, bribery, and other financial improprieties or illegalities.
- The NGO meets all of the legal obligations in the countries in which it is organized or works. Such obligations may include laws of incorporation, fundraising legislation, equal employment opportunity principles, health and safety standards, privacy rules, trademark and copyright legislation, and so forth.
- The NGO takes prompt corrective action whenever wrongdoing is discovered among its staff, governing body, volunteers, contractors, and partners.
The Organization complies with all applicable local, national, and international laws, including but not limited to:
- Data Protection Laws (e.g., GDPR, local privacy regulations) to safeguard personal and organizational data.
- Financial and Tax Regulations, ensuring full transparency in financial operations.
- Anti-Bribery and Corruption Laws, prohibiting any form of unethical financial transactions.
- Employment and Labor Laws, ensuring fair hiring, non-discrimination, and workplace safety.
Any staff member or representative found violating legal or ethical standards will be subject to immediate disciplinary action.
VI. Financial Stewardship
The organization manages its funds responsibly and prudently. This includes the following considerations:
- It spends allocated budget on programs in pursuit of its mission;
- It spends an adequate amount on administrative expenses to ensure effective accounting systems, internal controls, competent staff, and other expenditures critical to professional management;
- It compensates staff, and any others who may receive compensation, reasonably and appropriately;
- It has reasonable fundraising costs, recognizing the variety of factors that affect such costs;
- It ensures that all spending practices and policies are fair, reasonable and appropriate to fulfill the mission of the organization; and,
- It ensures that financial reports are complete and accurate in all material respects.
VII. Transparency and Disclosure
The organization provides comprehensive and timely information to the public and all stakeholders and is responsive in a timely manner to reasonable requests for information. All information about the organization will fully and honestly reflect the policies and practices of the organization. Basic informational data about the organization, reviews and compilations, and audited financial statements will be posted on the organization’s website or otherwise made available to the public. All financial, organizational, and program reports will be complete and accurate in all material respects.
VIII. Conflict of Interest
A conflict-of-interest situation arises when the “private interests” of the staff compete or conflict with the interests of the organization. “Private interests” means both the financial and personal interests of the staff or those of their connections including:
- family and other relations;
- personal friends;
- the clubs and societies to which they belong; and
- any person to whom they owe a favor or are obligated in any way.
Staff should avoid using their official position or any information made available to them in the course of their duties to benefit themselves, their relations or any other persons with whom they have personal or social ties.
They should avoid putting themselves in a position that may lead to an actual or perceived conflict of interest with the organization. Failure to avoid or declare any conflict of interest may give rise to criticism of favoritism, abuse of authority or even allegations of corruption. In particular, staff involved in the procurement process should declare conflict of interest if they are closely related to or have beneficial interest in any company which is being considered for selection as the NGO’s supplier of goods or services.
Appendix 1 provides some examples of conflict-of-interest situations, which may be encountered by staff.
Conflict of Interest Disclosure Process
To maintain transparency and prevent conflicts of interest:
- All staff, board members, and volunteers must complete an Annual Conflict of Interest Disclosure
- Form and update it if any new potential conflicts arise.
- Any individual with a disclosed conflict must recuse themselves from related decisions or discussions.
The Organization will review disclosed conflicts and take necessary actions to mitigate risks, including contract restrictions or reassignment of responsibilities.
IX. Program Evaluation
The organization regularly reviews program effectiveness and has mechanisms to incorporate lessons learned into future programs. The organization is committed to improving program and organizational effectiveness and develops mechanisms to promote learning from its activities in the field. The organization is responsive to changes in its field of activity and is responsive to the needs of its constituencies.
X. Inclusiveness and Diversity
The organization promotes inclusiveness and diversity in its staff, board and volunteers in order to enrich its programmatic effectiveness. The organization takes meaningful steps to promote inclusiveness and diversity in its hiring, retention, promotion, board recruitment and constituencies served.
XI. Confidentiality and Data Protection
It is the policy of the organization that board members and employees of “Institute of Liberal Politics” NGO will not disclose confidential information belonging to or obtained through their affiliation with the organization to any person, including their relatives, friends, and business and professional associates, unless the organization has authorized disclosure. This policy is not intended to prevent disclosure where disclosure is required by law.
Board members, volunteers and employees are cautioned to demonstrate professionalism, good judgment, and care to avoid unauthorized or inadvertent disclosures of confidential information and should, for example, refrain from leaving confidential information contained in documents or on computer screens in plain view.
Upon separation of employment and at the end of a board member’s term, he or she shall return, all documents, papers, and other materials, that may contain confidential information.
Failure to adhere to this policy will result in disciplinary actions, up to and including termination of employment or service with “Institute of Liberal Politics” NGO.
Any breach of confidentiality may result in disciplinary action, including termination of employment or affiliation with the Organization, as determined by the Board of Directors.
XII. Fundraising
In raising funds from the public, organizations will respect the rights of donors, as follows:
- To be informed of the mission of the organization, the way the resources will be used and its capacity to use donations effectively for their intended purposes;
- To be informed of the identity of those serving on the organization’s board and to expect the board to exercise prudent judgment in its stewardship responsibilities;
- To have access to the organization’s most recent financial reports;
- To be assured their grants will be used for the purposes for which they were given;
- To receive appropriate acknowledgement and recognition;
- To be assured that information about their donations is handled with respect and with confidentiality to the extent provided by the law;
- To expect that all interactions with individuals representing the organization will be professional in nature.
Ethical Fundraising Standards
In all fundraising efforts, the Organization commits to:
- Honest Representation – Clearly stating the intended use of funds in all fundraising materials.
- Refusal of Controversial Donations – Rejecting funding from sources that contradict the Organization’s values, including entities involved in human rights violations or corruption.
- Strict Donor Privacy Protections – Ensuring donor information is securely stored and used only for approved purposes.
XIII. Whistleblower Protection
The Organization encourages employees, volunteers, and stakeholders to report unethical behavior without fear of retaliation.
Reports can be made:
- Confidentially via a designated reporting channel (email or anonymous form).
- Directly to Board for urgent matters.
Without risk of retaliation, as the Organization prohibits any form of punishment against whistleblowers.
Any individual found retaliating against a whistleblower will face disciplinary action, up to and including termination.
XIV. Public Communications & Social Media Use
Staff and representatives must differentiate personal opinions from official Organization statements. Only designated spokespersons may issue public statements on behalf of the Organization. Employees and volunteers must avoid sharing internal information on social media platforms. Any violation of this policy may lead to disciplinary measures.
XV. Sustainability & Environmental Responsibility
The Organization recognizes the importance of environmental responsibility and commits to:
- Reducing paper use through digital documentation.
- Sourcing office supplies and event materials from eco-friendly suppliers.
- Implementing recycling and waste reduction programs in all workspaces.
Annex 1: Examples of Conflict-of-Interest Situations
Examples of Conflict-of -interest Situations
- A staff member takes part in the selection of suppliers or contractors, one of the bidders under consideration being his family member, relative or close personal friend.
- A staff member has a financial interest in a company, which is being considered for selection as the NGO’s supplier of goods or services.
- A staff member accepts frequent or lavish entertainment or expensive gifts from the NGO’s suppliers or contractors.
- A staff member serves, as a member of the NGO’s recruitment or promotion board, and one of the candidates under consideration by the board is his family member, relative or close personal friend.
- A staff member responsible for processing applications for admission to a home for the elderly operated by the NGO is considering an application from his family member, relative or personal friend.
“Institute of Liberal Politics” NGO
Conflict of Interest Disclosure form
I acknowledge that I, ________________________a
Board member, standing committee member or employee (highlight relevant one) of “Institute of Liberal Politics” NGO, have reviewed the “Conflicts of Interest Regulation” before signing this report.
I hereby disclose information on all associations (all business and charitable organizations), which may involveժ a possible conflict of interest and will furnish further details upon request.
Feel free to attach additional sheets if you need.
☐ I do not have any conflicts of interest at this time
Organization | Relationship |
| |
|
I also understand that I am required to disclose any other situation from which a possible conflict of interest might arise in the future.
Name:
Signature:
Date:
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.