Report on the results of the public public discussion of the draft Anti-Corruption Program of the Ministry of Internal Affairs of Ukraine for 2023 — 2025

07 March 2023

In accordance with Chapter V of the Methodology of Corruption Risk Management, approved by the Order of the National Agency for the Prevention of Corruption dated December 28, 2021 No. 830/21, and the Procedure for Consultation with the Public on the Formation and Implementation of Public Policy, approved by the Resolution of the Cabinet of Ministers of Ukraine dated November 03, 2010 No. 919 96, The Ministry of Internal Affairs of Ukraine held a public discussion of the draft Anti-Corruption Program of the Ministry of Internal Affairs of Ukraine for 2023 — 2025.

The information notice on the start of the public public discussion is posted on the official website of the Ministry of Internal Affairs of Ukraine on February 08, 2023.

Within the framework of the public public discussion of the draft Anti-Corruption Program of the Ministry of Internal Affairs of Ukraine for 2023—2025, a round table was held on the basis of the Dnipropetrovsk State University of Internal Affairs on February 22, 2023. The event was held in the form of a video conference.

The round table was attended by employees of individual structural units of the Ministry of Internal Affairs (Department for the Prevention of Corruption, Department of Education, Science and Sports, Department of Communication); authorized for prevention and detection of corruption of central executive bodies, whose activities are directed and coordinated is approved by the Cabinet of Ministers of Ukraine through the Minister of Internal Affairs of Ukraine, the National Guard of Ukraine, the Main Service Center of the Ministry of Internal Affairs and its separate structural units, institutions, institutions and enterprises belonging to the sphere of management of the Ministry of Internal Affairs ; representatives of international organizations, in particular the NATO Mission in Ukraine, the CMEA in Ukraine, and the public; trainees and students of the Dnipropetrovsk State University of Internal Affairs. A total of 185 people.

Information on the proposals received during the public public discussion and the results of their consideration are given in the table.

No. of sales/n Offer Information Author of the proposal Offer Consideration Information
1. In paragraph 1 (column 1) of Chapter IV “Improving the process of providing services to the Ministry of Internal Affairs” of Appendix 1 to the Anti-Corruption Program of the Ministry of Internal Affairs for 2023—2025 (hereinafter referred to as Paragraph 1), exclude the words “in the GSC of the Ministry of Internal Affairs”, since the GSC of the Ministry of Internal Affairs is not the executor of subparagraph 2 (column 2). A. Halchyshak, Chief Specialist of Corruption Prevention Department of the Ministry of Internal Affairs of the Ministry of Internal Affairs Taken into account.
2.

Paragraph 1 shall be supplemented by sub-paragraph 2 (column 2) as follows:
“Implementation of the project on assessing the quality of the provision of administrative services in the service centers of the Ministry of Internal Affairs using the web platform “Your GSC of the Ministry of Internal Affairs”, deadlines for execution (column 3) “Monthly until 05”, responsible for execution (column 4) “SCC of the Ministry of Internal Affairs, RSC GSC of the Ministry of Internal Affairs”, indicator of implementation (expected result) (column 5) “Prepared and sent to the management of the GSC of the Ministry of Internal Affairs informational and analytical materials on the state of implementation of the project”, sources of financing (column 6) “Within the limits of expenditures provided for in the state budget”

A. Halchyshak Chief Specialist of Corruption Prevention Department of the Ministry of Internal Affairs of the Ministry of Internal Affairs Taken into account.
3. On the introduction of the provisions of the Anti-Corruption Strategy for 2021—2025 and Measures for the Implementation of the State Anti-Corruption Program for 2023—2025 into the Anti-Corruption Program of the Ministry of Internal Affairs for 2023—2025, taking into account the deadlines for implementation O. Sagittarius, Commissioner for Anti-Corruption Activities of the National Academy of Internal Affairs Not taken into account. The
Anticorruption
Program of the Ministry of Internal Affairs for 2023—2025 will be amended within 30 days after the Government approves the State Anti-Corruption Program for 2023—2025
4. Proposal for improvement of Chapter III “Prevention of corruption in the field of public procurement, strengthening the efficiency of financial and material resources management, development and maintenance of the internal audit system” O. Sagittarius, Commissioner for Anti-Corruption Activities of the National Academy of Internal Affairs Taken into account.
5. Proposal for simplification of the numbering of measures in Appendix 1 to the Anti-Corruption Program of the Ministry of Internal Affairs for 2023—2025 “Measures to implement the principles of the anti-corruption policy of the Ministry of Internal Affairs, measures for the implementation of the Ministry of Internal Affairs Anti-Corruption Strategy for 2021-2025 and the State Anti-Corruption Program for 2023-2025” O. Sagittarius, Commissioner for Anti-Corruption Activities of the National Academy of Internal Affairs Not taken into account. The numbering
proposed in the draft anti-corruption program was used in previous anti-corruption programs. Such numbering does not contradict the law
6.

In Annex 1, paragraph 1 of Chapter VI of the Anti-Corruption Program, add the following content with sub-paragraph 3:
“3) Introduction of the discipline of education of integrity in the educational programs of educational institutions of the security and defense sector, in particular educational institutions of the Ministry of Internal Affairs”, set the deadline for implementation: in 2023 — “According to the deadlines specified in the Annual Work Schedule Ukraine Programme NATO Integrity Education Programme (VI Programme)”

M. Kohut, Coordinator of NATO's Integrity Education Program in Ukraine Taken into account.
7.

Proposal for mandatory technical control of vehicles

M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
8. Proposal for driver training and monitoring of driving school activities M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
9. Proposal for accreditation of driving schools and certification of specialists M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
10. Proposal for requirements for MTB and driving school specialists M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
11. Proposal for a typical training program M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
12. Proposal for the carriage of dangerous goods M. Serebryakov, Executive Director of NGO “Together Against Corruption” 23.02.2023 proposals withdrawn by the initiator
I'm 13. Proposal for incorrect and uncoordinated work of information and communication units of the Ministry of Internal Affairs IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption” Not taken into account. Said proposal does not
apply to the subject of discussion
14. Proposal for topical names of structural units of the Ministry of Internal Affairs that are executors of the Anti-Corruption Program IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption” Taken into account.
In
case of organizational and staff changes in the apparatus of the Ministry of Internal Affairs, the corresponding changes will be made to the Anti-Corruption Program of the Ministry of Internal Affairs for 2023-2025
15. Proposal on the feasibility of introducing electronic document flow (clarification of the wording of the measure of Section I of Annex 1) IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption”

Not taken into account. The introduction of
a single electronic document flow system in the system of the Ministry of Internal Affairs is one of the tools for improving and improving the efficiency of management activities in the system of the Ministry of Internal Affairs

I'm 16.

Proposal on the need to supplement Section II of Appendix 1 with measures in terms of personnel management, item 1 item 1 - visitation and detailed analysis of draft orders
on personnel issues (personnel)

IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption” Not taken into account. The Corruption
Risk Assessment Working Group at the Ministry of Internal Affairs conducted an assessment of corruption risks. According to the results of the work carried out, a number of functions (processes) potentially vulnerable to corruption were identified, including in the field of procurement, a number of risks were identified, they were included in the risk register, and measures were developed to eliminate or minimize them
17. Proposal for the implementation during the martial law of organizational measures using the ProZorro electronic procurement system during the state procurement procedure in the apparatus of the Ministry of Internal Affairs (Section III of Appendix 1) IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption” Not taken into account. The Corruption
Risk Assessment Working Group at the Ministry of Internal Affairs conducted an assessment of corruption risks. According to the results of the work carried out, a number of functions (processes) potentially vulnerable to corruption were identified, including in the field of procurement, a number of risks were identified, they were included in the risk register, and measures were developed to eliminate or minimize them
18. Proposal on the need to specify measures related to strengthening the efficiency of management of financial and material resources (Section III of Annex 1) IN. Martynenko, Head of the Civil Service “Center for Prevention and Counteraction of Corruption”

Not taken into account.
The organization of the implementation of tasks and activities is carried out according to the Appendix (Plan of measures for the modernization of the accounting and financial reporting system in the public sector for the period up to 2025) to the Strategy for the modernization of the accounting and financial reporting system in the public sector for the period up to 2025, approved Order of the Cabinet of Ministers of Ukraine dated June 20, 2018 № 437

I'm 19. Proposal for clarification of the deadlines for the implementation of certain measures provided for in Section IV of Annex 1 (monthly until the 30th) IN. Martynenko, Head of the General Staff “Center for Prevention and Combation of Corruption Taken into account.
I'm 20. Proposal to involve the public in the work of the working group on corruption risk assessment at the Ministry of Internal Affairs IN. Martynenko, Head of the General Staff “Center for Prevention and Combation of Corruption Not taken into account. The draft
Anti-Corruption Program provides for such a norm (item 4, paragraph 2, section II of Appendix 3)
I'm 21. Proposal to supplement the Anticorruption Program project with measures for conducting public anti-corruption expertise IN. Martynenko, Head of the General Staff “Center for Prevention and Combation of Corruption Not taken into account.
In accordance with the seventh part of Article 55 of the Law of Ukraine “On Prevention of Corruption”, public anti-corruption examination of current regulations and draft regulations can be carried out on the initiative of individuals, public associations, legal entities
He's 22. Proposal for electronic queues for services in territorial service centers of the Ministry of Internal Affairs IN. Martynenko, Head of the General Staff “Center for Prevention and Combation of Corruption Partially taken into account.
He's 23. Proposal for revision of corruption risks identified by the working group in the system of functioning of higher education institutions of the Ministry of Internal Affairs IN. Martynenko, Head of the General Staff “Center for Prevention and Combation of Corruption Not taken into account. The
anti-corruption program of the Ministry of Internal Affairs for 2023-2025 is a logical continuation of the implementation of the measures provided for by the Anti-Corruption Program of the Ministry of Internal Affairs for 2020-2022. Certain measures to eliminate/minimize corruption risks associated with the functioning of higher education institutions of the Ministry of Internal Affairs in 2022 for objective reasons were not fully implemented. Such measures were transferred to the Anti-Corruption Program of the Ministry of Internal Affairs for 2023-2025
He's 24. Proposal for the lack of interaction of the Ministry of Internal Affairs with the public O. Skrynsky, Chairman of CMV VNGO “Ukrainian Union of Persons with Disabilities — USI” Not taken into account. Said proposal does not
apply to the subject of discussion
I'm 25. Proposal for lack of transparency in procurement and automatic creation of corruption risks in the procurement procedure O. Skrynsky, Chairman of CMV VNGO “Ukrainian Union of Persons with Disabilities — USI” Not taken into account. The Corruption
Risk Assessment Working Group at the Ministry of Internal Affairs conducted an assessment of corruption risks. According to the results of the work carried out, a number of functions (processes) potentially vulnerable to corruption were identified, including in the field of procurement, a number of risks included in the risk register were identified, measures were developed to eliminate or minimize them
I'm 26. Proposal for the absence of anti-corruption program of the National Police of Ukraine on the official website of the National Police of Ukraine O. Skrynsky, Chairman of CMV VNGO “Ukrainian Union of Persons with Disabilities — USI Not taken into account. Said proposal does not
apply to the subject of discussion. At the same time, the Anticorruption Program of the National Police of Ukraine for 2022-2024 is posted on the official website of the National Police of Ukraine at the link: About police/Prevention and counteraction/Anti-corruption programs of NPU

 

Department for the Prevention of Corruption of the Ministry of Internal Affairs