Statute and five policies — published in full

We published the statute and five internal policies in full. Not as extracts, not "available on request", not a two-page scan.

What exactly is open

• The organisation's statute — 13 sections of the current edition
• Anti-corruption policy — aligned with the FCPA and EU norms
• Conflict of interest policy — written declarations for all governing-body members
• Safeguarding policy for vulnerable groups and minors
• Personal data protection policy
• Financial policy — budget, donor fund accounting, procurement thresholds, audit

Why do this before the first grant

The usual sequence runs the other way: an organisation receives money first, then a donor asks to see the policies, and they are written in a week to match that specific requirement. Such documents describe not how the organisation works, but what the donor wanted to read.

We did the reverse. The rules were written before the money existed, so they were not tailored to anyone. It also means anybody can hold us to our own documents.

What they actually say

• Gifts worth more than UAH 500 may not be accepted.
• Payments above UAH 50,000 require two signatures.
• Procurement above UAH 100,000 goes to a competition with three offers.
• Anyone who takes decisions declares their interests in writing once a year; if a matter concerns them personally they do not vote, and this is recorded in the minutes.
• Applications are kept for 24 months; a copy or deletion of your data is provided within 30 days.

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