POLICY FOR ATTRACTING FINANCIAL FUNDS

POLICY FOR ATTRACTING FINANCIAL FUNDS
PUBLIC FUND “OUR AGE”
Duration: 2026–2028
APPROVED
1. General provisions
1.1. This Policy establishes the rules for the search, evaluation, acceptance and use of financial resources of the Our Century Foundation (hereinafter referred to as the Fund), as well as requirements for transparency, independence and verification of potential sources of funding.
1.2. The Policy applies to grants, donations, institutional and project funding, corporate philanthropy and other legitimate forms of financial support.
1.3. The policy was developed taking into account the legislation of the Kyrgyz Republic and international practice of financial integrity.
1.4. The document uses the term “Due Diligence.” In the context of this Policy, this is an internal risk-based donor assessment process. It does not mean that all provided procedures are automatically the direct legislative responsibility of the NPO.
2. Legal and regulatory framework
The main special act in the field of combating the financing of criminal activities and money laundering is the Law of the Kyrgyz Republic of August 6, 2018 No. 87 as amended by the Law of January 23, 2025 No. 26.
For the purposes of this Policy, the following rules are especially important:

Important: Article 5 defines financial institutions and non-financial categories of persons subject to special regulation. Therefore, the Fund does not state in this Policy that Articles 19–22 automatically assign all responsibilities of an AML/CFT subject to the Nash Vek PF. The Fund voluntarily uses the relevant elements of risk-based practice as an internal standard, and the special obligations of NPOs are applied to the extent established by law, in particular Article 16.
3. Links to official lists and sources
Instead of including static lists in the text of the Policy, the Foundation uses the current official versions as of the date of verification.
• Consolidated sanctions list of the UN Security Council
• Consolidated sanctions list of the Kyrgyz Republic
• SFIS list of high-risk countries
• Law of the Kyrgyz Republic No. 87 dated 08/06/2018 in the current version
• Official website of the SFIS
• Official Consolidated List of UNSC Sanctions
4. Purpose and principles of raising funds
• legality and integrity;
• compliance with the mission and strategy of the Foundation;
• institutional and analytical independence;
• transparency of the origin and use of funds;
• diversification of funding sources;
• preventing conflicts of interest;
• proportionality of the inspection to the level of risk;
• refusal to finance if there is unacceptable legal, sanctions or reputational risk.
5. Independence of the Foundation
5.1. Receipt of funding does not grant the donor the right to determine or alter the results of the Foundation’s independent monitoring, research, analysis, and public materials.
5.2. The Fund does not accept conditions that require concealing identified violations, falsifying reports, changing independent conclusions, or refusing to legitimately criticize government agencies, international organizations, financial institutions, contractors or other entities.
5.3. Taking into account the profile of the Fund, funding from international financial institutions, the projects and activities of which the Fund independently monitors, is not accepted. The possibility of financing from other organizations indirectly associated with MFIs is assessed separately for conflicts of interest.
5.4. Funding must not create political dependence or an obligation to support a political party, candidate or political position.
6. Acceptable and unacceptable sources
Acceptable are grants and donations from international and private foundations, UN programs, bilateral donors, diplomatic missions, international NGOs, environmental and climate funds, responsible corporate sector and individuals, as well as other legitimate sources.
The Fund will refuse funding if the source cannot be reasonably identified, there is reasonable doubt about the legality of the origin of the funds, there is a confirmed sanction match, an unacceptable conflict of interest, a requirement to violate the law, or a significant limitation on the Fund’s independence.
7. Donor credibility check (Due Diligence)
7.1. The review is conducted before a significant agreement is signed or before funds are received when the nature of the financing allows it.
7.2. For a legal entity, if possible, the following are established: full name, country of registration, registration information, official website, management, ownership structure and beneficial owners, nature of activity and available information on sources of financing.
7.3. For an individual, when necessary due to the nature of the financing and the risk, the name, citizenship/country of residence and other identifiers necessary for reliable identification are established.
7.4. The inspection is carried out in proportion to the risk. For a regular grant from a renowned international foundation, a reduced review may apply; if there is an increased risk, additional information is requested.
8. Sanctions and country verification
8.1. The Fund checks the potential donor and, if necessary, related persons against the current Consolidated Sanctions List of the Kyrgyz Republic and the lists of the UN Security Council. Article 10 of Law No. 87 establishes a ban on the provision of funds to persons included in the Sanctions List.
8.2. If relevant jurisdictional or treaty applicability exists, US (OFAC), EU and other applicable sanctions lists are additionally checked.
8.3. Not only is the exact name of the organization checked, but also reasonably available spellings, names of directors and beneficiaries. Foreign names are verified in Latin whenever possible.
8.4. The country of registration and origin of funds is compared with the current SFIS List of high-risk countries. Article 18 of Law No. 87 provides for enhanced measures for AML/CFT entities when working with high-risk countries; The Fund uses this principle as an internal risk assessment guide.
8.5. The mere presence of a country on the list does not mean automatic refusal of any cooperation. It is the basis for enhanced assessment and documented decision.
9. Reputation check and conflict of interest
The presence of significant public information about corruption, fraud, criminal prosecutions, sanctions, serious litigation, human rights violations, environmental and social violations, as well as the donor’s relationship with the objects of the Fund’s monitoring are checked.
A person who has a personal or other conflict of interest in evaluating a donor discloses it and, if possible, does not participate in the relevant decision.
10. Evaluation of grant terms
Before signing an agreement, the Fund reviews the amount and currency of financing, objectives, budget, timing, allowable expenses, reporting and auditing requirements, refund conditions, termination, publicity, confidentiality, personal data, intellectual property, applicable law and dispute resolution.
The Fund does not accept obligations that it is objectively unable to fulfill, and does not accept conditions that contradict the law, the Charter or this Policy.
11. Decision to accept financing

The result is documented with a brief record: who was checked, when, what official sources were used, the result of the check, the risks identified and the decision made.
12. Management and accounting of financial assets
When attracting financial resources from the Nash Vek Foundation:
funds are used exclusively in accordance with their intended purpose, the approved budget and the terms of the agreement with the donor;
expenses are confirmed by relevant financial and primary documents;
project and other earmarked funds are accounted for in a manner that ensures their proper use, control and reporting;
It is not allowed to use funds for personal purposes, as well as for purposes not provided for in the agreement with the donor or the legislation of the Kyrgyz Republic;
If there is a significant change in financing conditions or risk level, the relevant risks are re-evaluated.
13. Documentation and storage
A donor/project dossier is compiled based on significant sources of funding. It may include registration information, audit results, references to official sources, copies of documents, correspondence on significant issues, agreement, budget and reports.
Screenshots can be used as additional confirmation of the date and search result, but do not replace official documents and links to sources.
If the Fund is subject to special legal requirements for storing documents, the deadline established by law is observed. For high-risk NPOs, Article 16 of Law No. 87 provides for the storage of the information and financial statements listed therein for at least five years.
14. Monitoring and review
Re-review is carried out when there is a significant change in the terms of the grant, the management or structure of the donor, the emergence of new sanctions, significant negative information, a conflict of interest or other circumstances that change the level of risk.
The policy is reviewed at least once every two years or earlier if legislation or significant international requirements change.
15. Responsibility
The Head of the Fund ensures general compliance with the Policy. Responsible persons ensure auditing, financial accounting, program reporting and document storage within assigned responsibilities.
16. Final provisions
The policy comes into force on the date of approval. If legislation or the terms of the grant agreement establish more stringent mandatory requirements, the corresponding requirements will apply. Issues not regulated by the Policy are resolved in accordance with the legislation of the Kyrgyz Republic, the Charter of the Fund and decisions of the authorized body of the Fund.

Regulatory and official sources
• Law of the Kyrgyz Republic dated August 6, 2018 No. 87, as amended dated January 23, 2025 No. 26
• Consolidated sanctions list of the Kyrgyz Republic
• Consolidated sanctions list of the UN Security Council (SFIS page)
• SFIS list of high-risk countries
• UNSC Consolidated Sanctions List (UN official website)
• PF “Nash Vek” – official website