ANTI-CORRUPTION POLICY
OF THE PUBLIC FOUNDATION “NASH VEK”
Effective period: 2026–2030
1. General Provisions
The Public Foundation “Nash Vek” adheres to the principle of zero tolerance for corruption, bribery, fraud and misuse of resources.
This Policy establishes the main principles and rules for preventing and addressing corruption risks in the Foundation’s activities. It applies to the Foundation’s management, employees, experts, consultants, project team members, members of the External Assistance Monitoring Group (GMVP), volunteers and other persons acting on behalf of the Foundation.
2. Key Principles
The Foundation conducts its activities based on:
- legality and integrity;
- transparency and accountability;
- independence of decision-making;
- objectivity and accuracy of monitoring and analytical work;
- prevention of conflicts of interest;
- responsible use of financial and other resources;
- fair and equal treatment of partners, experts and suppliers.
3. Zero Tolerance for Corruption
The Foundation does not tolerate:
- offering, promising, giving or receiving bribes;
- illegal payments or other improper benefits;
- fraud or misappropriation of funds;
- fictitious expenses, documents or services;
- use of Foundation resources for personal purposes;
- abuse of position or professional authority;
- concealment of a material conflict of interest.
4. Independence of the Foundation
Funding, cooperation or interaction with government authorities, international organizations, international financial institutions, contractors or other stakeholders shall not determine or alter the Foundation’s independent findings, monitoring results or public position.
The Foundation does not accept conditions that require the concealment of identified problems, falsification of findings or abandonment of an independent assessment of government authorities, donors, IFIs, contractors or other actors.
5. Conflict of Interest
Persons involved in decision-making on behalf of the Foundation must disclose any personal, family, financial or other circumstances that may affect the objectivity of a decision.
A person with a material conflict of interest shall not participate in the relevant decision, selection of a supplier, assessment of performance or preparation of an independent conclusion.
6. Gifts and Other Benefits
The Foundation does not permit the acceptance or provision of money, gifts, services or other benefits if they may influence the objectivity of a decision or create such an impression.
Symbolic gifts and ordinary business hospitality are permitted only where there is no expectation of a reciprocal service or decision.
7. Financial Integrity
Foundation funds shall be used exclusively in accordance with approved purposes, budgets, grant agreements and the legislation of the Kyrgyz Republic.
The Foundation does not tolerate fictitious expenses, double financing, unjustified payments, overpricing of goods or services, or misuse of funds.
8. Procurement and Engagement of Specialists
Suppliers, experts and consultants are selected based on professional competence, compliance with requirements, quality and reasonable cost.
Decisions must be made objectively and without personal interest.
9. Monitoring of Projects and Engagement with IFIs
In carrying out public monitoring, the Foundation maintains its independence from the subjects of monitoring.
The Foundation does not accept financial or other benefits from organizations whose activities it independently assesses where this could create a conflict of interest or undermine the objectivity of monitoring.
Identified problems and violations are reflected in monitoring findings regardless of the interests of stakeholders.
10. Reporting Possible Violations
Any person may report suspected corruption, fraud, conflict of interest or improper use of funds to the Foundation.
The Foundation seeks to ensure confidential handling of good-faith reports and does not tolerate retaliation against persons who report suspected violations in good faith.
11. Response to Violations
Where there is reasonable information indicating a violation, the Foundation reviews the circumstances and takes appropriate measures depending on the nature of the violation.
Where necessary, relevant payments or decisions may be suspended, an additional review may be conducted, an independent specialist may be engaged, or relevant partners, donors or competent authorities may be notified.
12. Responsibility and Review
The Director of the Public Foundation “Nash Vek” has overall responsibility for implementation of this Policy.
The Policy shall be reviewed at least once every three years or earlier if there are significant changes in legislation, the organizational structure or the nature of the Foundation’s activities.