Fraud Policy

Approved by the Board of NGO “West Cherkaschyna Tourism

and Hospitality Association”

May 10, 2019

of the NGO “West Cherkaschyna Tourism and Hospitality Association”


NGO “West Cherkaschyna Tourism and Hospitality Association” (hereinafter – “Association”) adheres to high legal and ethical standards. It is expected that all employees, as well as consultants, contractors, partner organizations and any other parties that have financial or trust relations with the Association, share this obligation. The purpose of this Policy is to determine the Association’s fraud prevention and detection policies, as well as the procedures to be followed if fraud is detected or suspected. Each fraud incident will be treated with zero tolerance.


Although the Criminal Code of Ukraine provides for a clear definition of fraud, in the public and charitable sectors the term is used to describe acts such as fraud, bribery, forgery, extortion, corruption, theft, conspiracy, misappropriation and concealment of property and intellectual property. For this policy, fraud can be classified as fraudulent for the purpose of obtaining unfair or unlawful financial gain or other unfair gain. However, fraud that does not intend to receive unfair profit or profit is contrary to the principle of integrity and is a violation of the Code of Ethics.


Fraud of any type is a threat to the good name of the Association and the funds for which it is responsible. Therefore, the Association seeks to eliminate any fraudulent activities in the organization and its partners, as well as to thoroughly investigate such cases.

The Association’s policy is to raise staff awareness of fraud risk, to establish and maintain controls aimed at preventing and detecting fraud, and to take effective action in the event of fraud detection or suspicion.

The Association believes that it is the duty of all employees to be honest at all times and to report any suspected fraud without delay. Therefore, the strict policy of the Association is that no employee is in any way harmed by the reporting of doubts.

Responsibility of the governing bodies of the Association

The Board of Directors of the Association is responsible for identifying major risks for the Association, as well as for ensuring that proper systems, procedures and controls are in place. Such systems and controls should reduce the likelihood of fraud, and further procedures should reflect the Association’s decisive reaction to suspicion or actual fraud.

Responsibility of the Association’s staff

The Chairman, with the support of the Members of the Board (directors), is responsible for the day-to-day management of the Association, and therefore for maintaining systems and controls aimed at minimizing fraud in the organization.

All directors are responsible for ensuring that, through the line management system, employees are aware of fraud risks, familiar with the type of misconduct that may be expected within their areas of responsibility, and warn of any signs of misconduct. Similarly, directors and line managers are responsible for keeping employees established to prevent and detect fraudulent activity.

All employees are obliged to act consistently and honestly and to report any suspected violations without delay.

Responsibility of all sub-grantees of the Association

The Association encourages all sub-grantees to have their own anti-fraud policy. Any sub-grantee without such a policy may, as an alternative, adapt the Association’s Policy. The anti-fraud provisions are part of all grant agreements between the Association and its sub-grantees.

Fraud Reporting Procedure – Association

An employee who is concerned about the actions of a colleague or colleagues and suspects that the fraud has been committed or scheduled should not give the suspect any idea of his or her suspicion as this could jeopardize any investigation. Fraud information must be immediately provided to the management in accordance with the Policy.

Fraud Reporting Procedure – sub-grantees of the Association

An employee of the Association who is concerned about the actions of the sub-grant recipients should first of all report their concerns to the Association’s management.

The procedure for responding to all reports of suspected fraud

If the responsible officer concludes that the allegations are significant, an investigation should be initiated. The official is responsible for determining the nature of any such investigation that should follow the Association’s internal investigation procedures.

Such an investigation is intended to establish the extent of the fraud, to identify the offender and to determine whether other persons are involved in the crime. It will also consider whether the fraud was carried out due to a lack of adequate systems and internal controls, or a problem due to an inability to comply with existing requirements.

Disciplinary penalty, administrative action

Failure to comply with existing requirements may be evidence of negligence on the part of management, and those responsible will be subject to proper disciplinary action. Serious negligence on the part of any manager or employee will be considered grounds for dismissal under the Labor Law of Ukraine.

The Association’s policy is that all cases of suspected fraud are notified to the relevant law enforcement agencies who may wish to pursue the necessary proceedings. In exceptional cases, the President may decide not to report it to the police, where, for example, such a report could potentially violate human rights through the political environment in that country. Regardless of whether the case is referred to the police or not, disciplinary action will be taken against the employee concerned which may result in dismissal.

A violation that is treated as unreasonable and harmful intent can be considered as an act of gross misconduct by the employee concerned. Disciplinary action that may result in dismissal will be taken against any employee who commits such an offense.