State Institution “Center for Licensing and Accreditation of Medical Organizations” ANTI-CORRUPTION POLICY
I. General Provisions
1. The Anti-Corruption Policy of the state institution of the Ministry of Health “Center for Licensing and Accreditation of Medical Organizations” (hereinafter — the Center; hereinafter — the Policy) is implemented to raise the level of anti-corruption culture within the Center and among its employees. It reflects employees’ commitment to high ethical standards as well as intolerance of corruption offences and the prevention of their commission in the activities of the central office and territorial representatives.
2. This Policy is developed with due regard to the Laws of the Republic of Uzbekistan “On Combating Corruption,” “On the Civil Service,” “On Conflict of Interest,” Presidential Decrees of the Republic of Uzbekistan dated 27 May 2019 No. PF-5729 “On Measures to Further Improve the System of Combating Corruption in the Republic of Uzbekistan,” dated 29 June 2020 No. PF-6013 “On Additional Measures to Improve the System of Combating Corruption in the Republic of Uzbekistan,” dated 6 July 2021 No. PF-6257 “On Creating an Environment of Zero Tolerance for Corruption, Drastically Reducing Corruption Factors in State and Public Administration and Expanding Public Participation,” Presidential Resolution dated 6 July 2021 No. PQ-5177 “On Additional Measures to Organize Effectively the Activities on Combating Corruption,” Cabinet of Ministers Resolution dated 14 October 2022 No. 595 “On Additional Measures to Ensure Compliance with Codes of Ethics by Civil Servants,” as well as recommendations of international organizations and best global practices in combating corruption, including the requirements and recommendations of the international standard ISO 37001:2016.
3. The main objectives of combating corruption at the Center are:
to achieve fundamental elimination of corruption in the Center’s structural units;
to foster intolerance toward corruption by raising employees’ legal awareness and legal culture;
to implement preventive measures against corruption in all areas of activity of the structural units;
to promptly detect corruption offences, suppress them, eliminate their consequences and the causes and conditions that contribute to them, and ensure the inevitability of liability for committing corruption offences.
4. The requirements of this Policy are equally binding on all employees of the Center’s central office regardless of position or function.
5. As an internal document, the Policy defines the key requirements and principles aimed at preventing and suppressing corruption-related offences in the activities of the Center’s structural units to achieve the above objectives.
6. Any person entering employment at the Center must familiarize themselves with this Policy against signature and comply with all its rules and provisions.
7. For the purposes of this Policy, the following basic concepts and terms are used:
employee — a natural person who has entered into employment relations with the Center on the basis of a labor contract;
affiliated persons — close relatives of a Center employee, as well as a legal entity in whose charter (authorized) capital such close relatives own shares or interests, or a legal entity in whose governing body such close relatives are a head or a member;
state bodies and organizations— bodies of state power and administration, local state authorities, state institutions, and organizations with a state share exceeding 50 percent (hereinafter — organization);
international events — events organized and held on behalf of a state body with participation of its official representatives and representatives of foreign states and international organizations for the purpose of establishing cooperation, developing relations and exchanging experience; including events related to visits of the delegation of the Republic of Uzbekistan abroad and visits of foreign delegations to the Republic of Uzbekistan;
official events — events organized on behalf of a state body with participation of its official representatives to achieve specific objectives (official reception, ceremony, meeting, conference, seminar, briefing, symposium, presentation, roundtable, etc.);
business trip — sending an employee by order (decision, instruction) of the head for a specified period to perform official duties and assignments outside the permanent place of work (within the Republic of Uzbekistan or abroad);
counterparty — any legal or natural person (other than in labor relations) that has entered into contractual relations with the organization;
corruption — unlawful use by a person of his/her official or service position to obtain material or non-material benefits in personal interests or in the interests of others, as well as unlawful provision of such benefits;
corruption risk — the risk that employees of the Center or third parties may commit corruption actions on behalf of or for the benefit of the organization;
corruption actions — receiving (demanding, extorting), offering or giving a bribe (including through third parties), receiving money, securities, other property, proprietary rights, property-related services, or unlawful use of official powers for other illicit purposes; unlawful “facilitation payments,” and other such acts;
corruption-related offence — an act bearing signs of corruption and entailing liability under the law;
internal anti-corruption control structure — an internal unit responsible for early detection and prevention of corruption, elimination of its causes and conditions, prevention of conflicts of interest, and fostering an attitude of zero tolerance for corruption;
anti-corruption system — a set of measures to prevent corrupt actions, violations of the legislation of the Republic of Uzbekistan on combating corruption, and of the Center’s internal documents, ensuring high professional and ethical standards of employees’ activities;
cronyism (a form of favoritism based on friendly ties) — use of power and/or influence to grant unlawful advantages to friends or trusted persons;
official (public official) — a person who permanently, temporarily, or by special authority performs functions of a representative of power or carries out organizational-administrative or administrative-economic functions in state bodies, self-government bodies of citizens, and entities regardless of ownership, authorized to perform legally significant actions; also a person performing such functions in an international organization or bodies of a foreign state;
conflict of interest — a situation in which a person’s personal (direct or indirect) interest affects or may affect the proper performance of official duties, resulting in a contradiction between personal interest and the rights and legitimate interests of citizens, organizations, society or the state (actual/potential conflict of interest);
localism — acting solely in local interests; hiring, rotation and appointment based on lineage/origin or relatives’ status irrespective of compliance with qualification requirements;
nepotism (kinship-based favoritism) — use of power and/or influence to grant unlawful advantages to close relatives or friends, including unwarranted rewards, hiring and appointments to the detriment of the Center’s interests;
facilitation payments — unlawfully provided money, property, proprietary rights, services and other benefits not envisaged by legislation or rules to ensure or expedite standard procedures;
clannishness — subjective, preferential and biased treatment based on belonging to the same lineage/dynasty;
favoritism — special favor and support given by those in power to certain persons or groups, often to the detriment of others; manifested as biased provision of advantages;
charity (charitable assistance) — voluntary gratuitous or preferential support to the Center by legal entities and individuals in the form of transfer of material or non-material assets, including money, performance of works, provision of services and other charitable support;
international organization — any international organization established by states, governments or other international organizations regardless of organizational form and powers (including regional economic integration organizations);
sponsorship (sponsorship assistance) — assistance by legal entities or individuals to the Center (sponsored institutions) by performing works, providing services, transferring property, including money, as a result of which mutual obligations arise toward the sponsor;
patronage — protection of an employee by a higher-level employee by creating favorable working conditions, taking their side;
close relatives — parents, brothers, sisters, sons, daughters, spouses, as well as the parents, brothers, sisters and children of spouses.
II. Core Principles of Combating Corruption
8. The Center’s structural units implement the anti-corruption system based on the following principles:
legality — measures to combat corruption are implemented in compliance with the legislation of the Republic of Uzbekistan, taking into account internationally recognized practice and the Center’s internal documents;
zero tolerance for corruption — an uncompromising attitude toward any forms and manifestations of corruption in all areas of activity; employees are prohibited from directly or indirectly participating in activities that may generate corruption risks;
openness and transparency — informing employees, counterparties and the public about anti-corruption measures adopted and implemented by the Center;
preventiveness and systemic approach — priority of measures aimed at eliminating the causes and conditions conducive to corruption actions and risks; aligning procedures with the level of identified risks; integrating anti-corruption measures into all functions and areas of activity;
inevitability of liability — employees who commit corruption-related offences are held liable irrespective of status or position, in accordance with internal documents and applicable law;
use of technological advances — striving to use modern integrated information systems in building the anti-corruption system;
right of direct access to management — each employee may, without hindrance, contact the head of the organization or the Internal Anti-Corruption Control Unit when possessing reliable and substantiated information about corruption offences;
continuous improvement — based on monitoring and control of corruption risks, the Center’s central office structural units continuously improve the effectiveness of the anti-corruption system.
III. Key Areas of Anti-Corruption Activities
1) Managing Conflicts of Interest
9. Employees must act with integrity and honesty in performing official duties and representing the Center’s interests, must not use their office for personal interests, and must avoid situations that lead to conflicts of interest. A conflict of interest arises when personal interest affects or may affect impartial performance of duties and objective decision-making and impacts (or may impact) the rights, legitimate interests, property and reputation of the Center.
10. If a conflict of interest arises, the employee must immediately notify his/her manager or the Internal Anti-Corruption Control Unit in writing.
11. To prevent conflicts of interest, employees must submit, within the established deadlines and procedure, a declaration of income and property to the tax authority at their place of permanent residence.
12. Upon recruitment and transfer, employees must annually, and as relevant circumstances arise, disclose information about personal interests that cause or may cause a conflict of interest. The disclosure and resolution procedure is governed by the Center’s “Regulation on Managing Conflicts of Interest.”
2) Receiving Business Gifts and Signs of Hospitality
13. All employees are prohibited, in connection with the performance of official duties, from accepting from individuals or legal entities any property, gratuitous services to the employee (or family members), gifts or signs of hospitality, loans, guarantees, sureties, rewards, cash or equivalents, securities, material assistance, or other inducements.
14. An employee may receive a gift during business trips outside the Republic of Uzbekistan, at international and other official events, including those held within the Republic of Uzbekistan, provided that:
it complies with the legislation of the Republic of Uzbekistan, internal documents of the Center and the “Regulation on the value of gifts permitted and the procedure for their disposal in connection with business trips and international and other official events by employees of the Ministry of Health”;
the gift’s value does not exceed **four base calculation amounts (BCA)**;
the gift is voluntarily presented by the donor in connection with a specific international or other official event;
the gift is accepted openly and transparently;
the gift does not damage the Center’s reputation;
the gift does not cause a conflict of interest or corruption risks, and does not create obligations that could influence impartial decision-making.
15. Perishable items (e.g., bouquets, sweets) and stationery sets (calendar, booklet, plastic pen, planner, notepad) presented at such events are not formalized as gifts and may be disposed of at the employee’s discretion.
16. Any gifts received by Center employees as part of state delegations or at official events, including abroad, that fail to meet any of the above requirements must be transferred to the Center’s ownership in the prescribed manner regardless of value.
17. Gifts presented on personal occasions (birthday, birth of a child) not related to official duties are regarded as the employee’s personal gifts. Exceptions include awards received for achievements in competitions, as well as gifts on state holidays, commemorative dates and other official events.
18. When presenting such gifts, the following requirements apply:
at least three employees of the central office must be present;
the presentation is accompanied by congratulatory remarks indicating the reason;
the total value of the gift (including all taxes and fees) must not exceed **four times the salary**;
expenses of a single employee for a gift to another employee must not exceed **one BCA** per occasion.
19. To avoid suspicion, employees are prohibited from accepting gifts or other material assets from employees of other state bodies and organizations, partners and counterparties, or any individuals and legal entities in connection with any holidays (birthday, birth of a child, International Women’s Day, etc.).
20. Gifts on behalf of the Center at international conferences, symposia and other business (official) meetings are made by order of the Director of the Center or his/her deputy.
21. If there is any doubt as to the legality of receiving a gift, any employee must seek advice from the Internal Anti-Corruption Control Unit.
3) Participation of Center Employees in Work-Related Events
22. Employees may participate in events (exhibitions, seminars, conferences, etc.) organized by invitation of international or other organizations subject to:
compliance with the legislation of the Republic of Uzbekistan, this Policy and other internal documents of the Center;
serving the legitimate interests of the Center or the inviting party;
absence of influence on decision-making by employees, and absence of hidden unlawful remuneration or intent to obtain improper advantages;
absence of reputational risks for the Center and the inviting/invited party if information on participation is disclosed;
conformity with generally accepted scientific and business practices and non-entertainment nature of the event;
reasonable content and cost; the event must not be excessively luxurious, extravagant, unusual, or occur too frequently.
23. If the organizer of a business event (seminar, symposium, roundtable, etc.) is the Center itself, such event must comply with this Policy.
4) Regulation of HR Processes (selection, promotion, incentives, ownership of property abroad)
24. Selection, attestation and performance evaluation of employees, as well as bonuses, allowances and other incentives, shall be conducted transparently, equally and objectively for all employees in line with this Policy’s principles and requirements.
25. Selection and appointment of candidates to the Center is carried out with comprehensive screening under the “Procedure for Determining Professional Fitness of Center Employees,” other internal documents, and the conflict-of-interest management procedure.
26. Employees making HR decisions (promotion, appointment, inclusion in the talent pool, etc.) are prohibited from granting any unwarranted advantages to candidates (employees).
27. Filling vacant positions is carried out through open competition according to the position’s requirements, with priority given to the candidate’s qualifications and professional/academic achievements.
28. Indicators and criteria for assessing employee performance shall be developed, and incentives shall be based on them. The indicators must be objective, transparent and open for employees to review.
29. Center employees are prohibited from engaging in entrepreneurial activity, being founders (participants) thereof, obtaining foreign citizenship, opening or maintaining accounts abroad, or owning real estate and other property outside the Republic of Uzbekistan. Exceptions include accounts opened for education, internships, or medical services, as well as property acquired before appointment and duly disclosed.
5) Service Inquiries and Reviews of Structural Units’ Activities
30. When conducting various service inquiries, reviews and monitoring (hereinafter — objects of review), employees of the Center and subordinate organizations must:
avoid conflicts of interest;
not conduct a service inquiry, analysis, monitoring or audit single-handedly;
not remain alone with responsible persons of the reviewed organization during on-site visits;
not misinterpret legislation to fabricate violations, nor intimidate personnel with referrals to law-enforcement or other state bodies;
not threaten representatives of the object of review;
not request documents or inquire into issues irrelevant to the scope of review;
ensure lawful and professional evaluation of each identified violation;
when appropriate, record violations by photo/video and enter related information into the Center’s information systems;
immediately report to the head of the working group and the Internal Anti-Corruption Control Unit any attempts by representatives of the object of review to offer a bribe or provide material assets/services to conceal violations;
treat representatives of the object of review impartially and in accordance with the Center’s code of conduct.
31. A separate commission shall be established to consider objections received regarding the results of reviews, studies and monitoring conducted by the Center.
6) Ensuring Transparent and Effective Interaction with Authorized State Bodies, Counterparties and Third Parties
32. The Center does not involve suppliers, contractors or other third parties to make payments or perform actions that violate this Policy or the legislation of the Republic of Uzbekistan.
33. In relations with counterparties the Center adheres to legality and transparency.
34. The Center implements fair, open and transparent procedures for selecting suppliers, contractors and other counterparties based on objective criteria, as well as a transparent procedure for determining the value of goods and services procured, in accordance with applicable legislation and internal documents.
35. In cooperation with counterparties, the Center:
verifies the reliability of a potential counterparty in accordance with the “Instruction on Counterparty Due Diligence” and legal requirements of the Republic of Uzbekistan, including whether the counterparty has been involved in corruption activities, and whether a conflict of interest with Center employees exists;
informs the potential counterparty, including the winner of a procurement procedure, of its anti-corruption principles and requirements by including specific anti-corruption clauses in the contract.
36. In cooperation with authorized state bodies (e.g., licensing, participation in specialized councils, approval of documents and objects), the Center ensures the transparency and objectivity of document reviews and, where necessary, requests additional information on the reasons for negative conclusions or other outcomes.
37. To ensure transparency and fairness, Center employees are prohibited from engaging in entrepreneurial activity, establishing business entities, being their founders (participants), or performing organizational-administrative or administrative-economic functions in business entities (except ownership of freely traded shares of joint-stock companies within statutory limits). Paid activities other than teaching, scientific and creative activities are also prohibited, except as provided by the laws and decisions of the President of the Republic of Uzbekistan.
7) Anti-Corruption Expert Review of Internal Documents
38. In conducting legal expert review of internal documents, the Center’s Legal Department identifies corruption-prone factors that create opportunities for corruption actions and removes such factors from the documents.
8) Introduction of New Technologies in the Center’s Activities
39. To minimize corruption risks, Center employees, where possible, perform functions and official duties using information technologies.
40. In conducting competitive tenders within public procurement, Center employees use information technologies and interact with bidders electronically online, enabling integration with other electronic systems.
9) Video Recording of Activities and Broadcasting
41. Audio and video cameras are installed in the Center’s buildings to monitor employees’ activities, and the recordings are reviewed by responsible employees of the Center.
42. The Center’s official websites host online broadcasts of certain processes with elevated corruption risks (e.g., employee interviews, testing, commission meetings).
IV. Elements of the Anti-Corruption System
1) Availability of Key Internal Documents
43. The system is based on:
this Policy;
the Code of Ethics;
the principles and requirements set out in the Regulation on Managing Conflicts of Interest.
44. The Center’s management must demonstrate exemplary top-level leadership.
45. The Director, deputies and heads of structural units must be role models of honest, fair and independent conduct toward subordinates, citizens and legal entities, thereby fostering intolerance toward corrupt actions.
46. The Director, deputies, adviser and heads of structural units demonstrate leadership by establishing and implementing effective anti-corruption measures and procedures in areas where corruption risks exist.
2) Identification and Assessment of Corruption Risks
47. The Center identifies and assesses corruption risks inherent in its activities, taking into account the specifics of functions of organizational structures, the Center’s interactions with other parties, as well as external and internal factors, in accordance with the Center’s methodology for assessing corruption risks.
48. Corruption risk assessment is conducted at least once a year. The results are reviewed by the Minister. Measures and procedures to mitigate identified risks are reflected in the Center’s Anti-Corruption Program (Road Map).
3) Responsibility for Anti-Corruption Activities
49. To build an effective anti-corruption system, the function of internal anti-corruption control is assigned to the Legal Department.
50. The Internal Anti-Corruption Control Unit operates under its Regulation and reports directly to the Director of the Center.
51. The Director provides the Internal Anti-Corruption Control Unit with sufficient independence and necessary resources.
52. The Human Resources Development and Management Department is responsible for systematic and timely collection, analysis and updating of information on employees’ close relatives in the scope and manner provided by the “Regulation on Managing Conflicts of Interest” and the legislation of the Republic of Uzbekistan.
4) Raising Awareness of Employees and Third Parties about the Center’s Policy
55. To reduce corruption risks and raise awareness, the Center posts this Policy and core information on anti-corruption measures on its official websites.
56. The Center undertakes efforts to inform and explain the norms of the Republic of Uzbekistan’s anti-corruption legislation and the implemented principles, measures and requirements through:
regular messages from the Center’s leadership on the official website and via other communication channels regarding the importance of employees’ compliance with adopted norms and requirements;
systematic training of employees on anti-corruption issues at least once a year with subsequent testing, according to a training plan;
mandatory familiarization of new employees upon hiring with this Policy and other internal anti-corruption documents of the Center, with initial briefing;
additional training programs for positions with elevated corruption risks; records of such trainings are kept by the HR Development and Management Department;
outreach and awareness-raising activities using audio/video materials and other content to increase awareness among Center employees and citizens and to foster zero tolerance toward corruption;
consulting by the Internal Anti-Corruption Control Unit on application of this Policy and implementation of anti-corruption measures and procedures;
active promotion of anti-corruption behavior by the Internal Anti-Corruption Control Unit in accordance with the approved training plan;
inclusion of anti-corruption clauses in employment contracts with new employees and upon review of existing contracts.
57. Anti-corruption clauses are included in contracts with counterparties, partners, donors and sponsors. Such clauses are incorporated into all Center contracts (except those concluded via e-shop or auction results). Anti-corruption clauses are added to contracts concluded prior to adoption of this Policy when terms are reviewed or upon initiative.
5) Monitoring, Control and Accountability
58. The Internal Anti-Corruption Control Unit carries out ongoing monitoring, control and evaluation of the effectiveness, sufficiency and proportionality of implemented anti-corruption procedures. Following the results, appropriate measures are taken to build the anti-corruption system at the Center.
59. Monitoring and control are conducted in accordance with the “Methodology for Monitoring and Controlling the Effectiveness of Anti-Corruption Procedures” and the Center’s internal documents.
60. Monitoring covers the following key areas:
analysis of the Center’s functions on issuing supervisory and permitting documents and of procurement processes for compliance with the legislation of the Republic of Uzbekistan;
monitoring the anti-corruption legislation applied in activities and recommendations of public authorities;
monitoring recommendations of international and foreign organizations on building and maintaining effective anti-corruption systems;
monitoring media reports about involvement of the Center’s leadership or employees in corruption, as well as similar information regarding the Center’s counterparties and partners;
selective monitoring of the Center’s internal processes and functions to identify ineffective controls and procedures, improve them and ensure reliability and efficiency of the system;
monitoring completeness and effectiveness of implementing the items of the Center’s Anti-Corruption Program;
reviewing employees’ compliance with anti-corruption requirements and procedures;
assessing employees’ awareness of the core anti-corruption principles and requirements.
61. The effectiveness of the system (absence of corruption risks) is assessed through internal audit, including control of compliance with established requirements and procedures at the Center and its structural units.
62. The results of monitoring and control are reflected in reports on the state of the anti-corruption system. The procedure for preparing and submitting reports is established by an internal departmental document.
6) Liability
63. Compliance with anti-corruption requirements and procedures is a duty of every employee within the scope of their job responsibilities. Employees bear personal responsibility for violating the requirements and procedures established by this Policy and other internal documents of the Center.
64. In line with the principle of zero tolerance for corruption, all Center employees are strictly prohibited from direct or indirect, personal or intermediary participation in any corruption actions, namely:
demanding, soliciting or receiving unlawful benefits; abusing official position; using powers contrary to the Center’s legitimate interests to obtain unlawful benefits for themselves or third parties;
inducing a public official or any other person to unlawfully perform duties (or to refrain) or to obtain unlawful advantages in someone’s interest, including offering, promising, authorizing or providing unlawful benefits (bribe, inducement);
charging, receiving or making facilitation payments;
mediating in bribery or commercial bribery, transferring unlawful benefits, assisting in reaching an agreement to transfer such benefits;
other actions/inactions with signs of corruption or contributing to its commission, including situations of conflict of interest.
65. Employees must inform their manager and the Internal Anti-Corruption Control Unit of any attempts to induce them to commit corruption actions, as well as of any known corruption actions by other employees.
66. For each substantiated suspicion of corruption actions by Center employees, a service investigation is conducted under the regulations and other internal documents, and in accordance with the legislation of the Republic of Uzbekistan.
67. Employees who violate this Policy, anti-corruption legislation and procedures bear liability regardless of position, length of service or other factors, within the grounds stipulated by the legislation of the Republic of Uzbekistan and the Center’s internal documents.
68. When corruption actions are identified, the Internal Anti-Corruption Control Unit analyzes the causes and conditions of their occurrence and continuously improves the anti-corruption system.
69. The Director of the Center is regularly informed about the results of internal investigations.
70. The Center cooperates with law-enforcement and other state bodies to detect and investigate corruption offences.
V. Reporting Corruption Actions
71. If doubts arise regarding the legality of employees’ actions or their compliance with ethical norms, in cases of suspected corruption or other violations, or substantiated suspicions thereof, information may be reported through the following channels:
Hotline — 1369;
Official website —clamo.uz;
Email — info@clamo.uz;
Mailing address— 10007, Tashkent, Mirzo-Ulugbek District, Parkent Street, 51;
Directly to the Director of the Center.
72. Within its powers and capabilities, the Center ensures confidentiality of information about a person who has provided substantiated information about a violation, except as provided by the legislation of the Republic of Uzbekistan.
73. The Center protects the interests of its employees and guarantees that there will be no retaliation (dismissal, demotion, discrimination, oppression, harassment, etc.) against employees who, in good faith, report suspicious behavior or possible breaches of this Policy.
74. All reports received via the Center’s channels are reviewed by responsible officials in a timely and impartial manner in accordance with the legislation of the Republic of Uzbekistan and internal regulations. If the information is confirmed, measures to encourage the applicant are taken.
75. Knowingly false reporting by an employee is regarded as a violation of this Policy and unethical behavior; the reporting person may be held liable in accordance with the legislation of the Republic of Uzbekistan and the Center’s internal documents.
VI. Final Provisions
76. This Policy may be reviewed and amended in the following cases:
when the legislation of the Republic of Uzbekistan in the field of combating corruption changes;
when ineffective control measures and procedures are identified, as well as when it becomes necessary to improve the comprehensive measures aimed at preventing and combating corruption in the Center’s activities;
when the Center’s organizational structure or functional specifics change, and in other cases.
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