On December 16, 2016, the "Procedure for Obtaining Consent to Terminate the Employee Responsible for Implementing an Anti-Corruption Program", approved by Decision No. 74 of the National Agency on Corruption Prevention (the "Agency"), dated October 7, 2016 (the "Procedure"), came into effect.

Application to terminate an employment agreement

In accordance with the Procedure, a company must submit a written application to the Agency to terminate an employment agreement (the "Application") with an employee responsible for implementing an anti-corruption program (the "Authorized Person"). There is no established form of the Application, however it should provide for certain information about the Authorized Person as well as the termination grounds.

Consideration of the Application

Pursuant to the Procedure, the Agency will consider the Application within 10 working days of receiving it. A copy of the decision must be sent to the employer's place of business within three working days of making a decision. An employer, in turn, must notify the Agency within two working days after issuing the order on the termination of the Authorized Person.

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By way of a reminder, the Authorized Person must be appointed at the companies that must implement an anti-corruption program under the law.