In recent years, Ukraine’s business environment has faced mounting integrity challenges — from corruption and regulatory hurdles to the destabilizing effects of war. Small and medium-sized enterprises (SMEs) faced challenges with a draft model code of conduct that fell short of international standards and lacked practical private sector input. A 2024 survey of businesses by the National Agency on Corruption Prevention (NACP) revealed an urgent demand for clearer anti-corruption tools, with respondents emphasizing the need for actionable guidance to strengthen compliance.
Recognizing this gap, the National Agency on Corruption Prevention (NACP) partnered with the United Nations Office on Drugs and Crime (UNODC) to revise the draft code in line with article 12 of the United Nations Convention against Corruption (UNCAC) and international good practices. UNCAC specifically calls on States to adopt integrity standards like codes of conduct to ensure ethical business operations, prevention of conflicts of interest, and sound commercial practices. The revised code now reflects these dual pillars - legal requirements under UNCAC and globally recognized anti-corruption measures.
UNODC led the revision process of the code by providing technical expertise and facilitating a collaborative platform involving NACP, the Ukrainian Network of Integrity and Compliance (UNIC) and the NGO “Foundation for Institutional Development” (FID). The substantive development of the code was supported by the guidance provided by UNODC in “An Anti-Corruption Ethics and Compliance Programme for Business: A Practical Guide”. As a result of the consultations held with businesses, civil society, and international experts, an updated model code of conduct was developed and adopted by NACP. The new code provides clear, actionable guidance for companies and SMEs to implement anti-corruption systems, emphasizing leadership commitment, ethical values, and accountability. Practical tools such as whistle-blower mechanisms, compliance audits, and employee training are also included to ensure effective adoption.
Antonina Prudko, Head of the UNIC Secretariat, highlighted the collaborative nature of this initiative: “Our collaboration with UNODC to develop the draft Model Code of Conduct is an excellent example of how anti-corruption initiatives can be turned into practical tools for businesses. Together, we have created a flexible and applicable guide that will help Ukrainian businesses to strengthen their compliance and promote a culture of integrity.”
The code is designed to serve as a flexible, business-driven tool to help companies seeking to strengthen their internal compliance mechanisms and contribute to national anti-corruption efforts. Its collaborative development process is a unique example of how collective action ensures that the framework is both practical and aligned with the needs of Ukrainian businesses.
Viktor Pavlushchyk, Head of NACP, emphasized the code’s importance: “This Model Code of Integrity is an example, and we want to present it to the private sector so that they can use it in their activities to reduce the level of tolerance for corruption in Ukraine and to develop compliance in the private sector.”
To promote the code’s adoption, UNODC organized workshops for over 80 compliance officers from nearly 30 companies. These sessions provided practical training on ethical decision-making and anti-corruption measures, equipping participants with the knowledge to implement integrity programmes.
The code has been widely endorsed, with the government publishing it on the NACP website for all businesses to access. The private sector has also welcomed the initiative. Nataliia Lysa, Legal and Compliance Director at Nestlé Southeast Europe, noted: “The Code is designed to provide guidance and direction in shaping corporate culture for private organizations of all levels. It is built on key elements like tone from the top, values, and clear standards of conduct.”
259 companies have engaged with the code via the NACP website and early adopters already report positive outcomes, demonstrating how ethics strengthen resilience amid regulatory challenges and wartime pressures. By leveling the playing field for businesses of all sizes, the code ensures that ethical practices become the cornerstone of corporate operations across Ukraine. These changes are not only transforming individual companies but also contributing to a broader cultural shift towards transparency and fairness in the marketplace.
