In accordance with the order of the Minister of Internal Affairs of Ukraine dated October 27, 2022 No. 139/18, the Ministry of Internal Affairs of Ukraine started the procedure for assessing corruption risks in its activities.
1. In order to determine the probability of committing corrupt and corruption-related offenses by employees of the Ministry of Internal Affairs, to establish the causes, conditions and consequences of the possible commission of such offenses, as well as to prepare the Anti-Corruption Program of the Ministry of Internal Affairs of Ukraine for 2023—2025 in accordance with the order of the Ministry of Internal Affairs of Ukraine dated October 27, 2022 № 139/18 “On the assessment of corruption risks and preparation of anti-corruption programs in the system of the Ministry of Internal Affairs for 2023—2025”, published on the official website of the Ministry of Internal Affairs, an assessment of corruption was carried out risks in the Ministry of Internal Affairs in the format of self-assessment in accordance with the Methodology.
2. The Order of the Ministry of Internal Affairs of Ukraine dated November 22,
2022 No. 764 “On the Formation of a Working Group on Corruption Risk Assessment in the Ministry of Internal Affairs of Ukraine” established a working group for the assessment of corruption risks, its personal composition and provisions on it were approved. The working group includes employees of independent structures units of the Ministry of Internal Affairs, anti-corruption experts of the European Union Advisory Mission to Ukraine and a lawyer.
3. In order to prepare for the assessment of corruption risks on November 25, 2022, an introductory training was held for the members of the working group in video conference mode with the involvement of representatives of the National Agency for the Prevention of Corruption.
4. The working group has drawn up a corruption risk assessment plan, which defines the stages of the working group's activities, taking into account the functions of the Ministry of Internal Affairs, its internal and external stakeholders, and other factors of the environment of the Ministry of Internal Affairs (minutes of the working group meeting of December 01, 2022).
5. In order to study the environment of the Ministry of Internal Affairs and determine the functions and processes vulnerable to corruption, the working group analyzed the following sources of information:
1) the results of the assessment of corruption risks for the previous period, the measures of their impact, the evaluation of the effectiveness of their implementation;
2) the results of an anonymous survey (questionnaire) of external and internal interested parties, the information received is summarized;
3) strategic activity plans, reform plans, development programs of new projects and other program documents of the Ministry of Internal Affairs;
4) the results of audits, inspections carried out against other organizations that perform similar functions or implement similar processes, summarize and document the collected information on possible facts of committing corrupt and corruption-related offenses, functions and processes with which such facts are associated;
5) materials of appeals and complaints regarding the activities of the Ministry of Internal Affairs, its individual employees, generalization and documentation of information on possible facts of committing corrupt, corruption-related offenses, functions and processes with which such facts are associated, frequency of receipt of complaints;
6) materials of disciplinary proceedings, official investigations; court decisions on bringing to administrative, criminal responsibility for committing corrupt and corruption-related offenses; court decisions in criminal, administrative, economic cases, in which other organizations performing similar functions were participants or similar processes, and their employees;
7) information contained in open information systems, registers and databases, including in the Unified State Register of Persons, about committed corrupt or corruption-related offenses, employees of the Ministry of Internal Affairs and employees of other organizations performing similar functions or implementing similar processes;
8) analytical materials of the National Agency for the Prevention of Corruption on the analysis of corruption risks, as well as analytical materials of other state, international, public institutions on the prevention and counteraction of corruption and other issues related to the activities of the Ministry of Internal Affairs;
9) analyzed information published in the media, social networks, other open sources of information on possible facts of committing corrupt or corruption-related offenses by employees of the Ministry of Internal Affairs and employees of other organizations performing similar functions or implementing similar processes.
6. Based on the collected and documented information, the working group identified the following functions vulnerable to corruption of the Ministry of Internal Affairs (minutes of the working group meeting of January 12, 2023):
Licensed activity:
ensuring, in cases stipulated by law, the licensing of certain types of economic activities and the exercise of control over compliance by business entities with the relevant licensing conditions;
provision of educational services:
establishing the procedure for selection, referral and enrolment for training in educational institutions belonging to the sphere of management of the Ministry of Internal Affairs and central executive bodies, the activities of which are directed and coordinated by the Minister;
provision on the basis of educational institutions belonging to the sphere of management of the Ministry of Internal Affairs, training and professional training of personnel for the Ministry of Internal Affairs, central executive bodies, the activities of which are directed and coordinated by the Minister, and the National Guard of Ukraine, in particular, the transfer of cadets (trainees) from training at the expense of individuals and legal entities for training for training by state order;
provision of administrative services (services of the Ministry of Internal Affairs):
accreditation of institutions that carry out training, retraining and professional development of drivers of vehicles;
taking exams for obtaining the right to drive vehicles and issuing relevant documents;
forensic expert activity:
conducting engineering and transport expertise (study of the technical condition of vehicles and registration documents);
management of the ministry:
organization and implementation of current and prospective planning, development of plans for the main organizational activities of the Ministry of Internal Affairs, the work of the Board of the Ministry of Internal Affairs, meetings of the Ministry of Internal Affairs management;
interaction with central executive bodies, the activities of which are directed and coordinated by the Minister;
Procurement:
ensuring the implementation of the tasks of the customer who carries out procurement in accordance with the Law of Ukraine “On Public Procurement” (procurement planning, formation of tender documentation);
financial management:
implementation of the Ministry of Internal Affairs as the responsible executor of budget programs functions for the formation of indicators of labor expenses in the estimates of institutions and institutions belonging to the sphere of management of the Ministry of Internal Affairs;
ensuring effective and targeted use of budget funds in the remuneration of employees of the Ministry of Internal Affairs.
7. During the assessment of corruption risks, the following methods and methods were used:
1) analysis of the sources of information given in p. 5;
2) analysis of regulatory and regulatory documents regulating the activities of the Ministry of Internal Affairs;
3) conducting a brainstorming, which consists in the open gathering and discussion of positions and ideas of interested parties — participants of brainstorming;
4) conducting individual communication (interviews) with employees and external interested parties of the Ministry of Internal Affairs;
5) modeling methods of committing corrupt or corruption-related offenses, determining internal and external interested parties who may participate in their commission.
8. Based on the results of the generalization of information and proposals received from internal and external stakeholders, the working group carried out identification, analysis, determination of corruption risk levels and measures of impact on corruption risks (minutes of the working group meeting of February 02, 2023).
For each measure of impact on corruption risk, the working group determines the executors of such measures, the term (term) and the indicator of its implementation.
Department for the Prevention of Corruption of the Ministry of Internal Affairs
