Profiles of Candidates for NACP Head

The competition for the selection of the NACP Head is approaching its two final stages: interviews for integrity and competence. Therefore, TI Ukraine analyzed these qualities of the applicants for this crucial position in the fight against corruption.

On February 9, the Commission for the Selection of the Head of the National Agency on Corruption Prevention will begin conducting integrity interviews with candidates. Prior to this, Transparency International Ukraine monitored all public information about the participants of the competition who reached this stage.

Our lawyers analyzed data from open sources, state registers, declarations, media reports, official responses of public authorities, reports of public and international organizations, autobiographies and motivation letters of candidates, etc.

We have analyzed data on 23 candidates out of 24. The exception is the profile of the candidate Andrii Vyshnevskyi, who headed the Board of Transparency International Ukraine from 2020 to 2022.

TI Ukraine experts studied the data on the property and assets of the participants, their possible ties with Russia, possible conflict of interest, disciplinary cases and more. As a result of studying all these materials, we formed our questions to the candidates and handed over all the materials we collected to the commission. The participants have already provided their explanations to some of these questions, so we hope to hear the remaining comprehensive answers during the interviews.

Stanislav Bronevytskyi

Education: in 2006, Bronevytskyi graduated from the Faculty of Law of Ivan Franko National University of Lviv

Position: Prosecutor of the Sixth Division of the Specialized Anti-Corruption Prosecutor’s Office of the Prosecutor General’s Office

Employment

He started his professional activity in 2006 as a lawyer at Teleinkom SE. That same year, he began working in law enforcement agencies as an investigator of the prosecutor’s office of Sokal district of Lviv Oblast, later the prosecutor’s office of Shevchenkivskyi district of Lviv and the prosecutor’s office of Lviv.

Since 2010, he held the positions of prosecutor in the prosecutor’s office of Lviv Oblast. In early 2013, he began his career in the bar, first as an assistant lawyer, then as a lawyer and director of Ex Yure law firm.

From 2020 to the present, he has been a prosecutor of the Specialized Anti-Corruption Prosecutor’s Office of the Prosecutor General’s Office.

Bronevytskyi is the procedural head in a number of high-profile cases of the NABU. In particular in the case of incitement by a lawyer of one of the defendants in the Zlochevskyi case about a super bribe of USD 6 mln to bribe the judges of the HACC, where the candidate Bronevytskyi unreasonably, in our opinion, insisted on the secrecy of the process of choosing an interim measure.

He actively communicates with the media and participates in professional events, including as a speaker.

The candidate might have been brought to administrative responsibility by a patrol officer of the National Police for violation of traffic rules (enforcement proceedings 65414371).

Our questions to the candidate

1. Does the candidate continue to be the owner/member of the Ex Yure law firm, if not, then why is the information about him still on the firm’s website?
2. Was/is Bronevystkyi really a member of the SPY detective agency, if not, then why is information about him still available on the agency’s website?
3. Does the candidate maintain ties with the political party Radical Party of Oleh Liashko, from which he ran for election in 2015?
4. What is the reason for the candidate’s desire, after more than 10 years of work in criminal justice, to head the NACP — a preventive body?
5. How does he plan to apply artificial intelligence to verify officials’ electronic declarations more comprehensively, as indicated in the motivation letter?
6. How exactly is it worth remembering about respect for human rights during the activities of the Head of the NACP? What shortcomings of the previous approach of the NACP management should be corrected in order to avoid excessive interference in the personal and family lives of officials?
7. Is it even possible to be a “single whole” with the SAPO and the NABU, as the candidate indicated in the motivation letter, given the different mandate and preventive role of the NACP in the anti-corruption ecosystem? If so, how exactly?   How does Bronevystkyi plan to prevent the negative impact of the previous prosecutor’s or lawyer’s worldview on the position of the head of the preventive body?

Vitalii Hatseliuk

Education: Candidate of Legal Sciences in 12.00.08 Criminal Law and Criminology, Criminal Enforcement Law

Position: Member of the High Qualification Commission of Judges of Ukraine

Employment

From 2007 to 2014, Vitalii Hatseliuk worked in the Secretariat of the Verkhovna Rada Committee on Legislative Support of Law Enforcement in the positions of Chief Consultant on Legal and Scientific Support and Deputy Head of the Secretariat.  From 2014 to 2023, he worked as a program manager for legal reform in the structure of the OSCE Project Coordinator in Ukraine.

Currently, Hupiak is senior fellow at the V.M. Koretskyi Institute of State and Law of the National Academy of Sciences of Ukraine, Department of Criminal Law, Criminology and Judiciary.

At the time of participation in the competition, he is a member of the High Qualification Commission of Judges of Ukraine.  He is also actively engaged in scientific activities in the field of criminal law.

Our questions to the candidate

1. Has the candidate encountered corruption in his scientific activity as a researcher at the V.M. Koretskyi Institute of State and Law of the National Academy of Sciences of Ukraine, in particular when defending theses? Since, unfortunately, this practice is widespread in Ukraine.
2. Why, despite such a strong motivation to become a member of the HQCJ soon after the start of the Commission’s work, did the candidate decide to apply for the position of Head of the NACP? Does he agree that it would be more ethical to remain a member of the HQCJ until the end of his term of office?
3. In 2022, the candidate stayed in the Quelle Polyana hotel in Zakarpattia Oblast for more than 183 days. The cost of one night’s stay in a single room at this hotel starts from UAH 2,000. That is, the candidate spent more than UAH 350,000 during that time.  We would like to clarify the circumstances under which and with whom the candidate stayed at the hotel and how much it cost him.
4. How did the candidate managed to buy an apartment of 47.1 sq. m. in Ukrainka in 2022 at a price about half of the market price?
5. According to the 2022 declaration, his son, a family member, rents an apartment in Spain, but did not provide information on the rental price. In addition, the candidate’s declarations do not contain any other information about the property that the son uses, owns, disposes of.  How is this justified?
6. The declaration for 2023 indicates the property of the wife of the candidate Evelina Hatseliuk. In particular, since 2022, she has owned a 2018 Lexus NX for UAH 1.2 million. How was such an expensive car purchased? The candidate did not indicate the information about the wife’s income in this declaration. Neither did he indicate the cost of her real estate in Uzhhorod.
7. DeJure covered the postponement of the HQCJ interview, which may have resulted in a recommendation for the resignation of the scandalous judge Andriyenko. According to DeJure, the Commission postponed the interview for questionable reasons: “On November 27, the judge came to the HQCJ for an interview, but the fourth panel of the HQCJ, Oleh Koliush, Vitalii Hatseliuk, and Ruslan Melnyk, postponed the consideration.  Even the judge was surprised by this decision.   The reason was that in 2021, the HCJ sent Andryienko for a qualification assessment, but as a disciplinary “punishment.” Now all members of the HQCJ will decide whether to assign the qualification assessment as a “punishment” or to continue the one that is already ongoing. The likelihood that the Commission will have time to consider this, conduct it, and refer a judge for dismissal is small.” How can the candidate comment on this case?
8. Should an updated NACP Code of Ethical Conduct be approved, or are the existing provisions of other documents applicable to civil servants sufficient? (question in view of the candidate’s position in the motivation letter)
9. How does the candidate plan to build a system of checks and balances in the transition from his membership in a collegial body to the sole head of the NACP?

Serhii Hupiak

Education: Yaroslav Mudryi National Law Academy of Ukraine, Bachelor’s degree with honors, issued on 30.06.2007; in 2012, a Master’s degree with the National Academy of Public Prosecutor’s Office of Ukraine.

Position: Head of the Fourth Investigation Department of the Territorial Department of the State Bureau of Investigation in Khmelnytskyi.

Employment

He worked in the prosecutor’s office in 2008-2013, from the position of an investigator to the position of a senior prosecutor. From October 2013 to March 2021, he held senior positions in the prosecutor’s office.

He voluntarily resigned from the prosecutor’s office in March 2021, in connection with the successful completion of the competition for a senior position in the bodies of the State Bureau of Investigation.

In 2023, Serhii Hupiak participated in the competition for the position of the NABU head in 2023, was among the three candidates presented to the Government.

After the appointment of Semyon Kryvonos as the head of the NABU, according to media reports, the Prime Minister of Ukraine Denys Shmyhal recommended that Kryvonos consider the possibility of appointing Serhii Hupiak and Roman Osypchuk to senior positions in the NABU.

The wife of the candidate, Olha Hupiak, a prosecutor of the department in the Vinnytsia Regional Prosecutor’s Office. She mainly specializes in cases related to the protection of the interests of the state, initiated as a result of the illegal withdrawal of land plots from state ownership.

Property status of the candidate

When considering the candidates’ declarations, we came across certain facts that needed to be clarified.

1. Substantial cash savings.

As of December 31, 2022, the candidate kept UAH 700,000 in cash. His wife, the prosecutor, kept USD 11,700 and EUR 7,000 in cash. As of late 2022, these amounts in foreign currency were equivalent to UAH 427,852.62 and UAH 255,980.2, respectively. That is, the total cash savings of the spouses can be estimated at about UAH 1,384,000.  The candidate has about UAH 26,000 in his bank accounts, and his wife has about UAH 16,000.

The difference between the income of a family of four for 2022 and the savings at the end of the year is about UAH 220,000.  It can be assumed that the family lived at the rate of UAH 4,600 per person per month. This raises questions about the origin of savings and ways to preserve them.

2. In May 2021, the candidate purchased a 2021 TOYOTA RAV-4 HYBRID worth UAH 929,787 together with his relative Tetiana Hupiak.

A question arises about the origin of funds for the purchase of this car, including in regard to the relative.

When participating in the NABU Director competition, such a question had already arisen and the candidate explained the origin of these funds.

Analyzing the declaration for 2021, when the candidate resigned from the prosecutor’s office, it seems there is no information directly about compensation for a leave, but there is information about the salary received by the candidate from the Vinnytsia Regional Prosecutor’s Office amounting to UAH 362,521. We would like to clarify how exactly the compensation for a leave is declared.

Our questions to the candidate

1. How does the candidate plan to use the powers of the Head of the NACP to prioritize inspections and monitoring of various categories of officials? (from the motivation letter on the deduction of corruption risks)
2. How did the candidate and his family manage to save UAH 700,000, USD 11,700, and EUR 7,000 in cash as of December 31, 2022, if the income for 2022 was about UAH 1,600,000, including taxes?
3. Is compensation for unused leave included in the salary of UAH 362,521 declared in the declaration for 2021 as received from the Vinnytsia Regional Prosecutor’s Office?
4. How does the candidate see the functions of the territorial departments of the NACP? What else should be improved in the Agency’s organizational structure? How should the NACP internal control system be developed? (from the motivation letter)
5. How should the Whistleblower Reporting Portal be optimized? (from the motivation letter)
6. Did the candidate have or does he have connections with politicians or government officials?

Ahia Zahrebelska

Education: In 2006, she graduated from the Donetsk Law Institute of the Luhansk State University of Internal Affairs, where she obtained the qualification of a specialist in law.  In 2011, she received a Master’s degree in jurisprudence at the National Academy of Internal Affairs.

Position: Deputy Chief of Staff of the NACP Apparatus

Employment

In December 2022, Ahia Zahrebelska joined the NACP team and headed the direction of minimizing corruption risks in the sanctions policy. Previously, she worked as a state commissioner of the AMCU, in particular, in the field of gambling business.

She led the investigation into the collusion of companies that participated in the procurement of food services by the Ministry of Defense in 2016 for a total amount of UAH 2.20 bln.  As a result of the investigation, the AMCU fined 22 firms in the amount of UAH 869.27 mln, which is the largest fine in the history of the AMCU among other cases of distortion of the results of tender bidding

She voted against allowing DTEK to acquire stakes in Odesaoblenerho and Kyivoblenerho, which increased the share of Rinat Akhmetov’s group in the electricity supply market.  She conducted an investigation into the actions of the Odesa City Council, which allowed Euroterminal to monopolize the possibility of paid passage of trucks to the territory of the Odesa Seaport.

Our questions to the candidate

1. Did Ahia Zahrebelska get acquainted with the conclusions set out in the report on the results of an independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does she agree with them? If she disagrees, with what exactly?
2. How does the candidate feel about the fact that she has been working for more than a year during the full-scale war as a deputy of an official who was a member of the Party of Regions and worked in a senior position in the Ministry of Family, Youth and Sports of Ukraine, the State Service of Youth and Sports of Ukraine, the Ministry of Youth and Sports of Ukraine during the entire period of the Yanukovych regime? Is she aware of any scandals surrounding these government agencies at the time? Is it ethical for such an official who ran for MPs on the list of the Party of Regions in the 2006 elections to continue to remain in the NACP in one of the senior positions under the new leadership?
3. The candidate heads the direction related to the sanctions policy. However, this direction is not included in the functions of the Agency under the specialized law or in general any other legislation. Therefore, we are interested in a number of questions about the work of this department.

• Does the candidate consider the sanctions policy to be an area that corresponds to the task and purpose of creating the NACP? Does she plan to maintain and expand this line of work in case of election to the position of the Head, despite the limited human resources of the Agency?
• Can the candidate name the regulatory acts that settle the formal stages and criteria for including or excluding legal entities from, for example, international war sponsors? Were there any scandals regarding the content of such a list in the work of the candidate, which would have a negative impact on Ukraine’s position? Has the Ministry of Foreign Affairs, international donors, or other stakeholders objected to the relevant activities of the NACP?
• Can the candidate name regulatory acts, which provide safeguards for the negative impact on the scope of the sanctions policy of the person whose deputy she is? If there are no relevant regulatory acts that would settle this process, what did Ahia Zahrebelska do over the past year for them to appear? Is the existence of such regulatory acts even necessary, according to the candidate, especially from the point of view of Article 19 of the Constitution of Ukraine? If the existing format for regulating the direction of the sanctions policy is successful or acceptable, according to the candidate, should the NACP extend this experience to other areas of the Agency’s activities?
• Does Ahia Zahrebelska consider Ukraine’s sanctions policy synchronized with the one of its partners? Does she see the problem in the fact that the sanctions lists of Ukraine and partners are incomplete, for example, despite the U.S. sanctions, Portnov, Kliuyev, and Sivkovych are still not under sanctions in Ukraine?

According to the ruling of the Solomianskyi District Court of Kyiv dated 24.07.2023 in case 760/3255/21, the husband of the candidate, Denys Zahrebelskyi, was accused of committing a crime under Article 125, part 1 of the Criminal Code of Ukraine.  However, on July 24, 2023, the victim in the case refused to support the prosecution, and therefore the proceedings were closed. Does the candidate know and could she explain why the victim decided to refuse to support the prosecution and the civil claim in the amount of UAH 1,000,000?

5. The candidate is an individual entrepreneur. In accordance with the position of the NACP, this is not a violation of the prohibition to engage in entrepreneurial activity established by Article 25, part 1, clause 1 of the Law on Prevention of Corruption if it is not actually carried out. At the same time, the NACP recommends ceasing the entrepreneurial activity of an individual entrepreneur to avoid any suspicion of a possible violation of the concurrent employment requirements. Does Ahia Zahrebelska agree with this recommendation of the NACP? Why didn’t the candidate cease her operation as an individual entrepreneur when she was appointed to the NACP more than a year ago? Did the candidate take any actions aimed at stopping business activities? Is the individual entrepreneur going to cease the operation in case of election to the post of head of the NACP?

* (clarification) Ahia Zahrebelska is not an individual entrepreneur. The operation of the individual entrepreneur was terminated in December 2022.

Dmytro Kalmykov

Education:

In 2007, he graduated from the E. Didorenko Luhansk State University of Internal Affairs and obtained a master’s degree in the specialty Jurisprudence. In 2010, he graduated from the Volodymyr Dahl East Ukrainian National University and received a master’s degree in Finance. In 2007–2011, he was a graduate student and a fellow of the E. Didorenko Luhansk State University of Internal Affairs.

Position: Head of the NACP Anti-Corruption Policy Department

Employment

Dmytro Kalmykov is the author of numerous scientific works, his sphere of scientific interests includes criminal law, criminal process. For a long time before joining the NACP, he cooperated with the NGO Center for Political and Legal Reforms.

For about 4 years, he has headed the Department of Anti-Corruption Policy of the NACP. It was this department that was engaged in the development of the State Anti-Corruption Program, which, although recognized as one of the achievements of the NACP and despite the extensive process of its public discussion, was criticized by the public due to the disregard of previously expressed relevant proposals and recommendations.

In his work, the candidate continued the negative practices supported by the leadership of the NACP, covered in the report on the results of the independent evaluation of the NACP.

Thus, in the second half of 2023, there were no public discussions of a number of the Agency’s regulatory acts that settled the important process of functioning of the monitoring system for the implementation of the State Anti-Corruption Program, developed by the NACP.  Accordingly, the public and other stakeholders were deprived of the opportunity to analyze the documents before their approval and present their recommendations for the improvement. The candidate at that time headed the department that developed Anti-Corruption Strategies and Programs, which can be called among the greatest successes of the NACP. Accordingly, the question arises whether the candidate agrees with this approach or he did not have sufficient ability to resist negative practices, the decision of which was supported by the management.

Our questions to the candidate

1. Dmytro Kalmykov has real estate in the temporarily occupied territory. Did he visit the temporarily occupied territories after their occupation?
2. Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them?
3. How does the candidate assess the implementation of the SAP today? What are the main challenges that he sees? Does the Agency manage to carry out its part of the activities despite limited human resources? What caused the non-consideration of proposals and recommendations of the public for improving the SAP, and why were public discussions of the Agency’s regulatory acts on the functioning of the SAP monitoring portal not organized?

Kateryna Kapliuk

Education: Bachelor’s degree with the Kyiv-Mohyla Academy in the specialties Culture and Journalism in 2004-2011; Master’s degree with the University of the State Fiscal Service in the specialty Law Enforcement in 2018-2020; Master’s degree with the National Academy of Internal Affairs in the specialty Law in 2021-2023.

Position: individual entrepreneur

Employment

Kateryna Kapliuk has been an individual entrepreneur since October 19, 2022. Before that, from January 2021 to October 2022, she was the chief specialist of the lifestyle monitoring department of the Department (Office) for conducting special checks and lifestyle monitoring of the NACP. The candidate came to the NACP after its reboot; first as an advisor to the Head of the NACP as not part of the staff in February-April 2020, and then as an advisor to the Patronage Service of the NACP until the end of January 2021.

In June 2021, the candidate received an appreciation certificate from the Head of the NACP for introducing lifestyle monitoring into practice. Later, the implementation of this procedure was recognized as unsatisfactory, with a corresponding non-compliance with the audit criterion 5.10. in the report on the results of the independent evaluation of the National Agency on Corruption Prevention for 2020-2021.

The candidate in her investigation for the Schemes program in 2016 called Oleksandr Amplieyev a “grandmother’s prosecutor” for the fact that he drove a Toyota Camry car that belonged to his 92-year-old grandmother from Zhashkiv. When asked by the journalist about how his grandmother saved for this car, Amplieyev replied that he shouldn’t have been asked this since he did not know how she saved moeny. In the finale of the investigation, the conclusion of the journalist was shown, stating that the study of the assets of prosecutors gave reason to believe that, firstly, they sometimes avoided the need to declare property, registering it with other members of their family. Secondly, even after officially declaring the use of elite property, the question of whether numerous real estate objects and expensive cars registered with relatives are legally acquired remained open.

In the lead-up to the story, it was shown that Oleksandr Amplieyev had been working in the prosecutor’s office for about 18 years, of which the last 12 he had been in the Prosecutor General’s Office.  In his declarations over the past three years, there are gaps—no apartments, no houses, no cars—but this year his situation has improved significantly.

In 5 years, the candidate worked in the NACP under the leadership of Oleksandr Amplieyev, who had been featured in her investigation. Amplieyev was heading the structural unit of the NACP for conducting special checks and lifestyle monitoring.

Our questions to the candidate

1. What caused the candidate to hold the position of advisor to the Head of the NACP as not part of the staff? What was the authority of the candidate for the position of advisor to the Patronage Service of the NACP? Which achievements in her work can the candidate note during this period? How exactly was the candidate appointed Chief Specialist of the Lifestyle Monitoring Department?
2. Did the candidate get acquainted with the conclusions set out in the report on the results of an independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does she agree with them? If she disagrees, with what exactly?
3. Kateryna Kapliuk managed several projects in the NACP related to the conclusion of the list of candidates for sanctions, as well as the search for the assets of such persons. Therefore, we are interested in a number of questions about the work of this department.

• Is the candidate aware that the Agency’s area of work related to the sanctions policy is not included in the Agency’s functions under the relevant law or other legislation? Does the candidate consider the sanctions policy to be an area that corresponds to the task and purpose of creating the NACP? Does she plan to maintain and expand this line of work in case of election to the position of the Head, despite the limited human resources of the Agency?
• Can the candidate name the regulatory acts that settle the formal stages and criteria for concluding a list of candidates for sanctions? If there are no relevant regulatory acts that would settle this process, what did the candidate do for them to appear? Are such regulatory acts even necessary, according to the candidate, especially from the point of view of Article 19 of the Constitution of Ukraine?
• If the existing format for regulating the direction of the sanctions policy is successful or acceptable, according to the candidate, should the NACP extend this experience to other areas of the Agency’s activities? Were there any scandals regarding the content of such a list in the work of the candidate, which would have a negative impact on Ukraine’s position? Has the Ministry of Foreign Affairs, international donors, or other stakeholders objected to the relevant activities of the NACP?

4. What has changed in the candidate’s views since her work as an investigative journalist that such a change allowed her to work in the NACP under the leadership of a former subject of her investigation? Does she now consider the activities of her former supervisor to be based on integrity? What is the candidate’s relationship with her former superior? Does the candidate support the practice when the subjects of journalist investigations continue to work in senior positions?

Oleh Kornienko

Education: Higher education, Yaroslav Mudryi National Law Academy of Ukraine in the specialty of prosecutor-investigator, legal counsel (2010).

Position: Head of the Department for the Prevention of Criminal and Other Offenses of the Office for the Prevention, Detection and Termination of Criminal and Other Offenses of the Military Unit (currently mobilized)

Employment

Oleh Kornienko has been a cadet of the Faculty of Law of the Yaroslav Mudryi National Law Academy of Ukraine since 2009. Since 2012- he began working in the military prosecutor’s office of the Sumy garrison of the Central region of Ukraine. In 2017 he began to work in the department of representation of the interests of the state, combating corruption in the military sphere and in the military-industrial complex of the Military Prosecutor’s Office and continued this path after mobilization.

Since 2023, he has been the head of the department for the prevention of criminal and other offenses of the office for the prevention, detection and termination of criminal and other offenses of the military unit.

Our questions to the candidate

1. The candidate participated in the competition for the post of deputy head of the ARMA and probably also participated in the competition for the post of head of the State Film Agency. Why did the candidate apply for positions in such different Agencies, and is now applying to the NACP? Why was he not selected in previous competitions?
2. Taking into account the fact that the candidate is a serviceman, the declarations for previous years are closed for the period of martial law. However, the declaration for 2022 does not indicate the value of any real estate owned: neither two land plots of 20,000 square meters in Sumy Oblast (acquired in 2016 and 2019), nor an apartment in Kyiv for 85.2 square meters (acquired in 2022). Why?
3. Together with his wife, they have almost USD 30,000 in cash. How did they manage to save such an amount?

Pavlo Kulyk

Education: higher education in the specialty Accounting and Audit

Position: Head of the Department of Analytical Work and Information Development of the Office of Information Systems, Analytical Work and Information Protection of the NACP

Employment

In 2015, Pavlo Kulyk worked as the head of the topographic service of the 46th Separate Special Forces Battalion Donbas-Ukraine, Armed Forces of Ukraine.

Since 2017, he has been a public servant. He worked in the Ministry of Temporarily Occupied Territories and Internally Displaced Persons of Ukraine, as well as in the National Agency for Civil Service. In 2020, he began his professional career in the National Agency on Corruption Prevention in the department of lifestyle monitoring and special checks.

He currently holds the position of Head of the Department of Analytical Work and Information Development of the Office of Information Systems, Analytical Work and Information Protection of the NACP.

Our questions to the candidate

1. In the motivation letter, the candidate indicates that the challenges the NACP team faces in the near future include:

• “To ensure the uninterrupted submission of declarations for 2023.” What does the candidate mean by this, given that on October 12, 2023, the Law of Ukraine No. 3384-IX came into force, which restored the mandatory electronic declaration and functions of the NACP?
• “To initiate full checks and ensure the proper pace of special checks.” Does the candidate support the automation of full checks, which was recently introduced by the Agency despite the conclusions set out in the report on the results of the first independent audit of the NACP?
• “To ensure the submission of political parties reports and resume verification of these reports.” What does the candidate mean by this, given the entry into force on August 23, 2023, of Law 3337-IX, which restores the obligation for political parties to submit reports, as well as the obligation of the National Agency on Corruption Prevention (NACP) to verify the reports?

2. Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them? Given that the candidate worked for 8 months as the chief specialist of the lifestyle monitoring department, what is his assessment of the findings of the report on this procedure? Does the candidate agree with the conclusions and recommendations of the TI Ukraine study on this procedure?
3. Does he support the new sanctions direction of the Agency’s work, despite the fact that it is not provided for in the specialized law? Does he consider it relevant to the task and purpose of the NACP?
4. Having been part of the NACP team, what weaknesses of the Agency can the candidate identify and how, in his opinion, can they be strengthened
5. Why did the candidate not indicate the value of three land plots of joint ownership, as well as a residential building and an apartment in use in the declaration for 2022?

Mykhailo Miroshnichenko

Education: Received a specialist diploma in law from the Academy of Customs Service in 2007, a Master’s degree in management (with honours) from Lviv Polytechnic National University in 2017.

Position: Acting Head of Odesa Customs.

Employment

Since 2007, he has worked in the State Customs Service. From 2015 to 2019, he was the Deputy Head of Lviv and later Zhytomyr Customs. Since 2020, he has worked as the Head of the Internal Audit Department of the State Customs Service. Since August 2022, he has been acting Head of Odesa Customs.

According to media reports, in 2020, the SBI conducted a series of searches at the premises of the Mykhailo Miroshnichenko, the Director of the Department for Combating Smuggling Ihor Reznik, and former Advisor to the Head of the State Fiscal Service Henadii Romanenko on suspicion of smuggling.

In January 2023, Miroshnichenko was suspended over a scandal involving embezzlement of funds from the export of Ukrainian grain. In April of the same year, the candidate was dismissed from the SCS. He is currently appealing the order for his dismissal. According to his autobiography, in April 2023, the candidate terminated his civil service due to the expiration of his contract.  However, according to the court ruling, the candidate’s civil service was terminated exactly because of his dismissal.

Since June 2023, the candidate has been active as a volunteer at the Charitable Foundation Tsil, which is registered in Lviv and was founded in 2013. The head of the charity is Lviv developer Yulian Poburko.

Our questions to the candidate

1. Why did the candidate’s wife refuse to provide information about her bank accounts, her monetary assets, as well as income from the alienation of movable property in 2015 and from doing business in 2022 for her declaration? Does the candidate to the position of the Head of the National Agency consider it ethical for his family member to conceal information subject to declaration?
2. Given the significant income for 2023, can the candidate clarify what type of entrepreneurial activity his wife is engaged in?
3. Why did the candidate indicate in his autobiography that he had terminated his civil service in 2023 due to the end of his contract, if the candidate’s civil service was terminated due to the dismissal he is appealing?
4. Did the candidate and his spouse use vehicles of third parties for free or paid for them?
5. What is the connection between the Candidate or his family members and the following people: Halyna Ivanivna Zubyk, Valentyna Yosypivna Miroshnichenko, Liudmyla Vasylivna Onyshchenko? Where did they get the relevant assets and funds from?
6. Did the SBI conduct searches in 2020 in Miroshnichenko’s premises? If so, then under which criminal proceedings were they conducted and what was the outcome? Is this search related tothe black grain schemes case?
7. How could the candidate continue to reside in Mohyliv-Podilsk, Vinnytsia region while working at Lviv and Zhytomyr customs offices during 2015-2019, as is indicated in the declarations for the relevant periods?
   If the candidate did reside at the place of work, why did he not include information about the use of housing in the declarations?
8. In 2015, the candidate owned two apartments in Mohyliv-Podilskyi, Vinnytsia region, on the right of partial ownership. In 2016, the candidate did not enter information about these objects in the relevant section of the declaration, while in the Income section there was only one entry about income from the alienation of real estate. Why was the information on the alienation of the second property not reflected?
9. Does the candidate’s volunteer activity mean he is constantly involved in the work of the charitable organization? It is unclear from open sources, as the candidate is not included in the list of founders and is not a member of the team. How does the candidate plan to continue such activities if he becomes the Head of the NACP?

Iryna Mostova

Education: lawyer. Kyiv Institute of Internal Affairs at the National Academy of Internal Affairs of Ukraine, 1999-2003

Position: attorney at law, Credence Partners Law Firm

Employment

Prior to working as an attorney, the candidate was a deputy and then head of the Department for Monitoring Compliance with the Law on Conflict of Interest and Other Restrictions on Prevention of Corruption until the NACP was “rebooted” in 2016.

Page 96 of the 2019 Shadow Report on Evaluating the Effectiveness of State Anti-Corruption Policy Implementation described the use of an unfair scheme under which most of the Agency’s senior positions were mass filled without competitive procedures.  One of the examples included the candidate and her appointment as Head of the Department. The report explained that the manipulations took place in several areas at once. One of the questions was whether NACP employees were given an advantage by the competition commission.

Another issue is that all persons who won the competition were immediately transferred to other positions after their appointment, and all of them, without exception, agreed to such transfers, which is hard to imagine in real life, except when it comes to prior agreement and planning of such actions. One more fact is that the candidate who came second in the competition for the head of the department was immediately appointed to the position of the head after the winner was transferred.  The author of the report noted that both parties to the process, the candidate and the NACP, violated a number of civil service principles described in Article 4 of the Law on Civil Service, namely: legality; professionalism; integrity; ensuring equal access to civil service and transparency.

In the 2019 Shadow Report on Evaluating the Effectiveness of State Anti-Corruption Policy Implementation experts noted that various types of statistical information provided by the NACP in its reporting on the work of the Agency in 2017 had no data on the results on court reviews of protocols. This looked rather strange to the experts, since this indicator is one of the key ones in terms of assessing the effectiveness of the NACP’s law enforcement activities. Experts noted that the reason for this situation was most likely the Agency’s reluctance to draw attention to this information, since the results of court reviews of protocols drawn up by the NACP employees were clearly not in their favor.

Cases on administrative offenses under Art. 172-7 (violation of requirements for prevention and settlement of conflict of interest) of the Code of Administrative Offenses (46 protocols in total) amounted to only 24%. Almost half of all cases (49.7%) under Art. 172-7 of the Code of Administrative Offenses were closed. At the same time, 52% of such cases were closed due to the absence of an offense, and 34% due to the expiration of the time limit for imposing a penalty.  Taking into account this data, the experts came to the natural and disappointing conclusions and stated that in 2017-2018 the NACP did not perform its administrative and jurisdictional function in terms of combating administrative offenses. The most common reason cited was the NACP’s disregard for the requirements for the content of protocols, which entailed the need for the courts to return the case files to the NACP for proper processing and led to violation of the time limits provided for in Article 38 of the Code of Administrative Offences, which was why proceedings on administrative offenses were subject to closure.

What raised greatest concern of the experts was disappointing statistics during the candidate’s leadership of this NACP structural unit related to cases of accusations of bias and persecution based on external instructions by NACP officials during inspections. The experts recommended to develop and approve an inspection procedure with a clear definition of the rights and obligations of NACP officials during the inspection, deadlines, grounds for and extent of liability in case of improper performance of duties, etc., and to conduct a proper assessment of corruption risks that may cause low efficiency of the NACP in this area, but this never happened.

The explanatory note for the 2019 draft law on “rebooting the NACP,” introduced by the President of Ukraine, states that the very need to develop the draft law was caused primarily by the ineffective work of the National Agency on Corruption Prevention. It is stated that the unprofessional and ineffective management of the National Agency results in discrediting the activities of the anti-corruption bodies established in Ukraine, which has been repeatedly indicated by both public and international organizations due to confirmed cases of interference with the activities of the National Agency. To ensure that the National Agency works effectively it must be and be perceived as an institution independent of any political interference, both in law and in practice.

The first public calls for a reboot of the NACP were made in March 2017. Back then, several CSOs, including Transparency International Ukraine, released a statement saying that the NACP was clearly being used to selectively prosecute individual declarants and activists. The then head of the NACP herself agreed to give the agency a “C” grade in August 2017.

Civil society activists additionally reported high-profile failures of the NACP where led by the candidate. The NACP, in its turn, released the Anti-Manipulator, document, where it said that the readers were forced to conclude that the NACP was ineffective in identifying conflicts of interest.

The law firm, in which the candidate works, offers such a service as protecting clients from pressure from the NACP in cases of corruption and corruption-related offenses. In one of her publications, the Candidate proposes that verification of declarations and monitoring of judges’ lifestyles be moved to the judiciary following the decision of the Constitutional Court of Ukraine No. 13-r/2020 of 27.10.2020. However, this particular decision was very scandalous and even caused a constitutional crisis.

Our questions to the candidate

1. Does the candidate support President Volodymyr Zelenskyi’s point of view on the ineffective work of the NACP in 2016-2019 and, accordingly, the need to “reset” the NACP? How does the candidate assess the work of the NACP during the time when she held a senior position in one of the most important areas of the Agency’s mandate?
   Does she consider her work at the NACP in 2016-2019 to be effective?
2. Did the candidate realize that the NACP’s actions were far from the standards of openness and integrity when she was appointed to the position of the Head of the Department and the relevant competition was held? Does the candidate recognize that she has violated a number of civil service principles? Does the candidate consider herself a model of integrity?
3. Is the Candidate aware of scandals, political interference, and corrupt practices in the Agency at the time? If so, how did the candidate react to them? Why didn’t the candidate stop her work in the NACP after them, but stopped her work there only with the “reset” of the agency? Does she consider it ethical if the new Head of the NACP is an official who worked in the NACP before the “reset”?
4. Does Mostova have or did she have any connections with politicians or government officials?
5. How does the candidate assess the decision of the Constitutional Court of Ukraine dated 27.10.2020? Does the candidate agree with the conclusions of the Venice Commission on this decision?
6. How actively did the candidate carry out her bar activities because her income amounted, in accordance with the declaration for the past year, to a salary of UAH 65,000 and dividends of UAH 80,000?
7. Does Mostova see a conflict of interest if she becomes the Head of the NACP, since she has represented clients in court disputes with the NACP? Does she see any risks if she is appointed to the position and her colleagues continue to work in the law firm and protect clients from pressure from the NACP?

Vitalii Nikulin

Education: The Yaroslav Mudryi National Law University, National Technical University Kharkiv Polytechnic Institute.

Position: Representative of the Commissioner for Human Rights in Places of Detention

Employment

Prior to his appointment as a representative of the Commissioner for Human Rights in places of detention, Vitalii Nikulin worked for a long time in the Kharkiv City Council, in particular as the head of the advertising department. He defended his thesis on Administrative and Legal Support for the Activities of Local Self-Government Bodies on Advertising.

Our questions to the candidate

1. In his declaration for 2022, Vitalii Nikulin indicates the city of Kyiv as his actual place of residence. This is consistent with the fact that as of 2022, he held the position of Director of the Department for Monitoring the Observance of Information Rights at the Secretariat of the Ukrainian Parliament Commissioner for Human Rights, which is located in Kyiv. In addition, in the Income, Including Gifts section, the candidate indicated an IDP accommodation allowance of UAH 35,000. Thus, it can be concluded that the Candidate had to relocate from Kyiv. However, the declaration in section 3 Real Estate Objects does not declare any housing in Kyiv: neither owned, nor rented, or used.
   How can the candidate explain this?
2. In his declaration for 2022, in the Income, Including Gifts section, Vitalii Nikulin indicated income from the alienation of movable property in the amount of UAH 350,000. Also, on October 25, 2022, he filed a declaration of significant changes in his property status, where he indicated the same income. The declaration for 2022 indicates a sale and purchase (exchange) transaction on October 25, 2022, the subject of which was a vehicle. Analysing the declarations, we can conclude that the transaction included a 2012 Volkswagen Touran worth UAH 195,000. Does the Candidate confirm this? If so, how did he manage to sell it for almost twice as much? Since it was an agreement of exchange, did he receive anything in return other than money?
3. The Candidate owns an apartment in Chystyakove (Torez), Donetsk region. Since 2014, this territory has been temporarily occupied. Has the candidate visited this city or other TOT since 2014?
4. How exactly, in the candidate’s opinion, should the “positive developments of the NACP team” be continued, taking into account the comments and suggestions of the European Commission, the Council of Europe, the practice of the European Court of Human Rights, etc., since the Candidate mentions this in the motivation letter?

Oleksandr Novytskyi

Education: In 2008, he graduated from the Private Higher Educational Institution Kyiv International University with a degree in International Relations. In 2012, he graduated from Taras Shevchenko National University of Kyiv with a qualification of political scientist-internationalist, English translator, junior researcher in international relations, specialty International Relations.

Position: Chairperson of the State Architectural and Construction Inspectorate of Ukraine since June 2023.

Employment

He started his career as a civil servant at the Kyiv Regional State Administration (2013), the State Registration Service of Ukraine (2014–2015), and subdivisions of the Main Territorial Department of Justice in the Kyiv Region (2015–2017).

He worked in the NACP in 2017–2021.

From June 2021 to October 2022 worked as a Chief Specialist of the Electronic Systems and Services Implementation Division of the Department of Services of the State Architectural and Construction Inspectorate of Ukraine (SACI).
From October 2022 to June 2023 took up the position of Director of the Department of Services of theState Architectural and Construction Inspectorate of Ukraine.

On March 7, 2023, at a meeting of the Government, it was decided to appoint Oleksandr Novytskyi as Acting Deputy Chairperson of the SACI. Since June 2023, he has been the Chairman of the SACI.

Questions to the candidate (property part)

1. According to the declaration, the candidate’s wife, Oleksandra Melnyk, received a salary at her main place of work in 2021 and 2022 from the SACI. At the same time, the candidate himself worked at the SACI since 2021, and since October 2022 – as the Director of the Service Department at the SACI. Was the wife subordinate to her husband? Was there any assistance from the candidate in the employment of his wife? Was there any conflict of interest in this situation?
2. Why did the candidate not submit the declaration for 2021 and 2022 earlier on his own initiative? What is the candidate’s attitude to the institution of declaration, how does he plan to develop it? What is the candidate’s attitude to the legislative “reset” of the NACP in 2019? Does the candidate believe that his work in the NACP and the performance of the NACP in 2017–2019 was effective? Is the candidate aware of scandals and corrupt practices in the Agency at that time? If so, how did the candidate respond to them? Why did the candidate not stop working at the NACP after they occurred? Does the candidate consider it ethical if the new Chairperson of the NACP is an official who worked at the NACP before the “reset”?
3. According to the declaration, in 2012, the candidate, together with his relatives Tetiana Novytska and Olha Novytska, jointly owned an apartment in Simferopol, but its value is not indicated. The value of the following property is neither indicated in the declarations for 2016-2020: a 2007 car PEUGEOT 207, purchased on October 11, 2014 (owned by the candidate’s wife), a car VOLKSWAGEN TRANSPORTER, purchased on July 02, 2013 (owned by the candidate’s father-in-law). Why is the value of this property unknown? Has Novytskyi visited the temporarily occupied territories after 2014?
   Does he hold Russian citizenship?
4. In 2021 the candidate’s wife purchased a FORD ESCAPE vehicle (made in 2015) for only UAH 148 295.
   How did she manage to buy a car for such a modest price?
5. According to the declarations, in 2017, the family of the candidate’s wife and she herself acquired land plots, the value of which is unknown: land plot of October 13, 2017, with an area of 0.23 m2 (wife), land plot of October 13, 2017, with an area of 3.84 m2 (father-in-law), land plot of October 13, 2017, with an area of 0.25 m2 (mother-in-law), land plot of October 13, 2017, with an area of 0.12 m2 (wife). Based on what grounds was this property acquired and why is its value unknown?
6. According to the declaration, in 2018 the candidate’s wife acquired a residential house worth UAH 1 486 000. However, there is a discrepancy: the date of acquisition was indicated as December 31, 2018, and the value was UAH 1 486 498 in the declaration for 2018. And in the declaration for 2019, the date of acquisition is May 11, 2018, the value is UAH 1 486 000. What were the grounds for the acquisition of the property, and how was its value determined? What caused the discrepancies in determining the value in different years?
7. There is also a question about the declaration of a residential building with an area of 291.5 m2 in the village of Hnidyn (owned by the candidate’s mother-in-law): in the declaration for 2016, it is listed as an object of unfinished construction, and in the declaration for 2017, it is declared as real estate, but the value is unknown and the date of acquisition is indicated as January 29, 2002. What is the reason for the discrepancy?

Relationship with the law

The actions or inactivity of the candidate himself were not appealed, but since March 2023, the portal Judiciary has contained information on a number of cases in which decisions, actions or inactivity of the SACI, which is headed by the candidate, are appealed.

Open sources revealed information dated November 30, 2023, about possible corruption related to the commissioning of the unfinished Avalon Prime residential estate complex.
The article mentions the names of the candidate, Deputy Minister of Community Development, Territories and Infrastructure of Ukraine Natalia Kozlovska and her assistant Olha Danchuk. The material contains a link to a post by Viktor Hleb about the candidate’s possible involvement in corruption.

Our questions to the candidate (regarding the report of the Accounting Chamber)

1. According to the Report of the Accounting Chamber for the first half of 2023, with the approved maximum number of employees of 660, the average percentage of vacant positions was almost 60 %. The resulting savings in the payroll fund made it possible to allocate free funds to establish super-high amounts of incentive payments for employees (600–1,490% of the official salary, for some chief specialists – 600 %, which led to significant disproportions in remuneration), which did not correspond to the contribution of employees to the overall work results. According to estimates, UAH 319.3 million, was spent; that is, almost 45% of all state budget allocation for the maintenance of the SACI.How can the candidate comment on this statement? Has such practice been eliminated under the candidate’s leadership at the SACI as of today? Does the candidate believe that such bonuses contribute to the corruption prevention or were there other reasons for such a decision? Does he know of any similar practice of saving the NACP’s salary fund? Does he plan to apply such bonuses in the NACP? Which criteria were used to distribute the bonuses, considering that in 2021, 2022 and the first half of 2023, the SACI conducted only 112 inspections?
2. According to the Report of the Accounting Chamber for the first half of 2021, the establishment of the Public Council of the SACI, which started in the fourth quarter of 2022, was not completed at the time of the audit. Has such a council been formed as of today? If not, what measures are being taken by the SACI and the candidate as its head to establish it? What is the candidate’s attitude to the institution of public councils and what policy does he pursue in this regard? How does this correspond with the candidate’s statement in the interview about openness to dialogue? How can the candidate evaluate the work of the Public Council at the NACP? What steps can the candidate propose to improve the NACP’s cooperation with it?
3. According to the Report of the Accounting Chamber for the first half of 2023, unscheduled measures, including those initiated by citizens, were not carried out in all cases.
   Only 4.2 % of appeals regarding possible violations in the field of urban planning during the period under audit were followed up by state architectural and construction control activities. How can the candidate comment on this parameter? Has this parameter been growing during the period of his management of the SACI? What are the criteria for determining the reasonableness of appeals? How does the candidate plan to work with reports from external actors on possible violations of anti-corruption legislation as Chairperson of the NACP? Which problems in this process does the candidate propose to solve in the NACP and how?
4. According to the Report of the Accounting Chamber for the first half of 2023, a number of issues were identified in the SACI in the field of staffing. The level of qualification and training of SACI staff, including state inspectors of construction control and supervision, did not meet modern safety standards and practices in construction. Specialists without the necessary higher specialized education and relevant work experience have often been appointed to positions in specialized structural units. Was the candidate, as the head of the SACI, aware of this problem and what measures did he take to solve it?

Coverage of the SACI work in 2023 in open sources: scandalous cases

The media and social networks have unofficially confirmed information about the alleged actions and decisions of the SACI in 2023, which caused some citizens to question the legality and integrity of these decisions (posts and materials mentioned the Avalon Prime residential complex, 4U residential complex, O2 Residence, the building of the SSU in Holosiivskyi Forest, etc.). These circumstances require clarification and verification of the accuracy of the facts presented.

1. Potentially negative case – Construction of the SSU in Holosiivskyi Forest in Kyiv

In the publication by Mirror of the Week of November 5, 2023, with reference to urban planning expert Heorhii Mohylnyi, journalists reported that the construction of houses in Holosiivskyi Forest was being resumed, with more than 300 apartments claimed by the Security Service of Ukraine.

Earlier in 2016, Mirror of the Week published an article about the risks and signs of illegality, the “corruption component” of this construction.

2. Potentially negative case – probably, no significant violations were recorded in the refusal to issue a certificate of acceptance for the O2 Residence

On September 12, 2023, Serhii Zadvornyi published an article “How prosecutors hide crimes of the President’s friends!“ According to the letter from the prosecutor’s office, quoted in the article, there was a risk that the SACI would issue the permit despite other significant violations. The author notes that over the years, this construction has been repeatedly mentioned in the media, and has been the subject of investigations by the media and law enforcement agencies.

• info – Vavrysh-Bohdan’s Orbit is building up almost 30 hectares of “recreational” land of the Ministry of Internal Affairs
• Net – Bohdan and Vavrysh’s company builds up 30 hectares of “recreational” land of the Ministry of Internal Affairs.
• Net – Bohdan “made together” Zelensky in response to the searches of his partner Vavrysh by the State Bureau of Investigation
• Nashi Groshi – Vavrysh and Bohdan’s driver are building up the recreational area of the Ministry of Internal Affairs under the “Mykyta” scheme.

3. Potentially negative case: possible assistance of the SACI in legalizing the construction of the 4U residential complex

On October 27, 2023, the Kyivvlada portal published an article by Ivan Kulik “With the help of the KCSA and SACI: The National Police is investigating violations during the construction of the 4U residential complex in the capital.”

4. Expectation of actions from the SACI to rectify the situations of its precursors

According to the information published in the article “Competition for naive idiots from the NABU. The Government Appointed the NABU Director” of March 6, 2023 by Ivan Pravdin, it is stated:
“In October 2021, the SACI continued to surprise the community when it suddenly effectively legalized the construction of the controversial 50Avenue residential complex at 50a Peremoha Avenue in the capital.”

Another article by Viktor Bondar and Yaroslav Falko, “The Secret of the Green Fence: There are No Guilty, but Victims!” published on the Voice of Ukraine website on March 16, 2023, clarified, in particular, the following:
“It is known that the SACI promised to check the legality of construction at 50-a Peremoha Avenue. We look forward to the result.”

It also states: “The customer of the construction activities is Exxon Premier Shuliavska, which in 2019 started building a residential complex in the territory of the Slava Tankistam park, next to the Shuliavska metro station, without the appropriate permits. The Sixth Administrative Court of Appeal satisfied the appeal of the Department of Urban Planning and Architecture of the KCSA, banning any construction at 50-a Peremoha Avenue near the Shuliavska metro station. The project included the construction of two towers, the tallest of which would have reached 51 floors.”

Our questions to the candidate (part about cases of SACI activity)

1. What does the candidate know about the apartment building on Kastelivtsi Street – Akademika Sakharova Street in Lviv (Avalon Prime residential complex)?
   Has it been accepted into operation and was it completed at the time of acceptance? Has the candidate ever had any contact with Olha Danchuk, Assistant to the Deputy Minister of Development of Communities, Territories and Infrastructure of Ukraine Natalia Kozlovska, on issues related to this facility?
2. How can Novytskyi comment on the statements of some authors that the SACI has issued a permit for project documentation for construction in Holosiivskyi Forest (9 Potekhina Street)? Are there any violations of the law at this facility, and what decisions did the SACI make regarding this facility in 2023? Were there any opposing decisions regarding this facility in November 2023?
3. On August 18, 2023, did the SACI really issue a certificate of completion for the first building of the 4U residential complex (2 Akademika Bulakhovskoho St., Novobilychi residential area) in Kyiv?
   Didn’t the SACI see any violations in this construction, such as failure to take into account the functional purpose of the land plot? Is the candidate aware of any criminal proceedings related to the possible theft of property of the Institute of Technical Thermophysics of the National Academy of Sciences of Ukraine at this construction site?
4. How can Novytskyi comment on the statements of some authors that the SACI practically does not include significant deficiencies (only those that can be corrected) in the refusal to issue a certificate of completion of an object? Wasn’t this the case with the refusal to issue a certificate of completion for O2 Residence? Is the building of this facility viewed as a violation of the intended purpose of the land plots, or as a non-compliance of the Urban planning conditions and restrictions granted to the developer with the urban planning legislation?
5. Does the SACI plan to check the legality of the construction at 50-a Peremoha Avenue (50Avenue residential complex), which, according to some authors, was carried out by Exxon Premier Shuliavska, on the territory of the Slava Tankistam park?
6. When the Cabinet of Ministers appointed the candidate for the position of the Head of the SACI, was there any support from politicians/political forces/authorities that influenced this decision? How did the candidate get this position?

Roman Norets

Education: In 2002, he graduated from the National Academy of the Security Service of Ukraine with the educational qualification level Specialist, specialty Jurisprudence and obtained the qualification of a lawyer with knowledge of English.

Position: works in the Security Service of Ukraine

Employment

From June 2002 to January 2020, he worked in the SSU in operational and managerial positions. From January 2020 to August 2023, he was the head of the department and unit of internal control of the NACP. Since August 2023, he returned to the Security Service of Ukraine.

The Mirror of the Week publication mentions “a shocking case, which the daughter of the head of the Internal Control Department of the NACP made public on social networks.”

Our questions to the candidate

1. How can the candidate comment on the above-mentioned publication of Mirror of the Week, and the corresponding situation that has received publicity on social networks? What is the candidate’s relationship with his family members, including former members, given the court decisions adopted against the candidate? What was the reason that the candidate stopped working in the NACP? Did the SSU pay attention to the material by the Mirror of the Week publication and the relevant situation which gained publicity on social networks before hiring the candidate in August 2023?
2. Did the employees of the structural unit, which the candidate headed in the NACP, provide formal or informal instructions to employees of other structural units regarding their direct activities as authorized persons of the NACP?
3. Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them? If he disagrees, with what exactly? Should, for example, additional safeguards and mechanisms be used in the procedure to verify the declaration of the Head of the NACP? If so and they are sufficient, what did the candidate do to establish them?
4. How did the candidate manage to separate the internal control functions in his structural unit and the corruption prevention functions, which by their nature have a greater advisory component than the controlling one? Did the candidate see any contradictions in such a combination of the functions of his structural unit? In the candidate’s opinion, did the specialaized Law on Prevention of Corruption allow such a combination?
5. Did the candidate keep personal contacts with the SSU representatives while working in the NACP? Did the candidate see a conflict of interest in the fact that its structural unit was engaged in the verification of declarations of SSU representatives, including in closed mode? Did the Law on Prevention of Corruption allow such an audit by the structural unit of Norets?
6. What mechanisms were there for civil society, international partners, independent auditors to oversee that the structural unit headed by the candidate checked the declarations of representatives of the SSU, the NABU, etc.? Did the candidate contribute to the implementation of such mechanisms in practice? Are such mechanisms needed at all, according to the candidate? Were violations of the requirements of the anti-corruption legislation by the former head of the Security Service of Ukraine and the former head of the Main Department of Internal Security of the Security Service of Ukraine found during the verification?

Viktor Pavlushchyk

Education: in 2008 he received a diploma of a specialist of the National Academy of the Security Service of Ukraine, specialty Jurisprudence, qualification of a lawyer with knowledge of English.
In 2014, he received a diploma of a specialist with Taras Shevchenko National University of Kyiv, specialty International Business, qualification of an international economist.

Position: Senior Detective — Head of the Detectives Department of the National Anti-Corruption Bureau of Ukraine

Employment

After graduating from the National Academy of the Security Service of Ukraine in 2008-2015, he served in the Security Service of Ukraine in operational and management positions.

Since 2015, he has been working in the National Anti-Corruption Bureau of Ukraine, currently as a senior detective — head of the detective department of the National Anti-Corruption Bureau of Ukraine.

In 2023, he participated in the competition for the director of the NABU. During the interview in the NABU competition, the commission had questions about his parents’ real estate. The commission had many questions regarding the person with whom the candidate lived together with, her relatives and the property acquired by them, there was also a question about the trip of the partner’s mother to Russia in 2020.

In autumn 2023, he also submitted documents for participation in the competition for the position of a member of the High Council of Justice.

Our questions to the candidate

1. The Unified State Register of Court Decisions contains a resolution of 2019 on the recognition of the candidate guilty of committing an administrative offense under Article 124 of the Code of Administrative Offenses. The candidate did not appear at the court hearing. Why didn’t he do it? Was it not important for him to protect his rights and interests before the court??
2. During the interview in the NABU competition, the candidate was asked about administrative offenses, as well as whether he followed the reporting policy for such cases. The candidate answered that he did so regarding the administrative offense that occurred in 2019. He could not remember if this was the case with the administrative offense committed in 2023. The candidate’s reporting a case of the administrative offense in 2023 needs clarifying.
3. The candidate applied to the court for an explanation of the court decision, but the court refused to explain. Did Pavlushchyk agree with this decision, if not, why didn’t he file an appeal? Why was the information on a criminal offense not immediately entered into the Unified Register of Pre-Trial Investigations by collective report No. 7389 dated June 27, 2019, on the grounds of criminal offenses provided for in Art. 382, parts 2, 3; Art. 364, part 2; Art. 396 of the Criminal Code of Ukraine?
4. The mother of the person with whom the candidate lives together, Tetiana Vodopianova, had a trip to Russia in 2020. The candidate was already asked about the purpose of this trip at the interview for the NABU director, at that moment he did not answer, indicating that it was the first time he heard about it and that he did not have such information.  Did he manage to find out the purpose of such a trip?
5. What is the relation between the candidate and Liubov Marholych, in whose apartment his place of registration is indicated in the declaration?
6. Last year, the candidate already participated in the competition for the director of the NABU and also submitted documents for participation in the competition for the position of a member of the High Council of Justice. According to the candidate, why was his candidacy not selected in previous competitions? Why did he decide to participate in this competition for the post of head of a preventive body, after participating in the previous ones?
7. The candidate’s declaration for 2022 lacks data in the section on monetary assets, and in the declaration for 2023, the declarant and his partner’s cash savings alone amount to about USD 19,000 and more than UAH 100,000. Were these assets accumulated for 2023, or was there an error in the 2022 declaration?

Serhii Podhorets

Education: In 2008, he graduated from Yaroslav Mudryi National Law Academy of Ukraine and received a full higher education in the specialty Jurisprudence and obtained the qualification of a lawyer.

Position: SAPO prosecutor.

Employment

He supports the public prosecution in high-profile cases against the ex-Director of Boryspil airport, as well as the unlawful provision of a stabilization loan to VAB Bank. In 2022, a reprimand was imposed on him for missing the deadline for appealing the HACC acquittal.

He is the head of the United Hearts of People Charitable Foundation.

His wife is a lawyer.

Our questions to the candidate

1. What does the United Hearts of People Charitable Foundation do and how does the candidate manage to combine prosecutorial work and work in the fund?
2. In the publication “Decriminalization of illicit enrichment: policy or rule of law?” Podhorets uses the term “decriminalization” instead of “recognition as unconstitutional.” Does the candidate distinguish between these concepts?
3. The candidate was brought to disciplinary responsibility for missing the deadline for appealing the HACC acquittal. When asked by the Qualification and Disciplinary Commission of Prosecutors, the candidate said that he disagreed with the position of the SAPO leadership and the senior group of prosecutors in this criminal proceeding on the need to appeal the verdict, as he considered it justified and legitimate. Then if the candidate considered the verdict of the HACC, which acquitted the ex-official of the Volyn Regional State Administration, lawful, why did he prepare and file an appeal?
4. The common-law wife of the candidate – Tetiana Chasova – in June 2022, together with Oleksandr Kovalenko, purchased a land plot of 15,000 square meters in Zakarpattia Oblast for UAH 124,213, as well as an unfinished house in Mukachevo with an area of 92.3 square meters. Due to the prevalence of the surname Kovalenko, it was not possible to find out detailed information about him.
   The candidate should clarify the circumstances of his common-law wife’s acquisition of a land plot and a house in Zakarpattia oblast.
   In 2023, it can be concluded from the declaration of Podhorets that this house was put into operation, and the wife of the candidate became the owner of 100% of the rights to it. Under what circumstances did this happen?

Volodymyr Podorozhko 

Education: higher; National University of the State Tax Service of Ukraine, Faculty of Tax Militia, Law Enforcement; Dnipropetrovsk Regional Institute of Public Administration of the National Academy of Public Administration under the President of Ukraine, Public Governance and Administration

Position: Manager of the Executive Office of the Zaporizhzhia Regional Council

Employment and property

Since 2016 he has been holding the position of manager of the executive office of the Zaporizhzhia Regional Council. According to the Ukrainski Novyny media, the candidate was associated with the pro-Russian political force Opposition Bloc, which is currently banned in Ukraine.

He was an assistant on a voluntary basis to the MP of the VIII convocation (2014-2019) Ihor Shurma.

The candidate was also a member of the Ternuvata village council of the Novomykolaivskyi district of Zaporizhzhia Oblast during 2019-2020.
In 2020, he ran for election as a candidate for member of the Zaporizhzhia Regional Council from the political party Order.

In his declaration for 2022, in particular, he declared an apartment of 73 m2 in Zaporizhzhia, as well as a car manufactured in 2017. The salary for 2022 was UAH 826,610, and he also keeps UAH 587,000 in cash. The candidate’s wife receives payments for IDPs’ living allowance from the Department of Social Policy of the Executive Committee of Ivano-Frankivsk City Council.

The candidate did not support the ban on the Ukrainian Orthodox Church of the Moscow Patriarchate – he provided written comments on the draft decision of the Zaporizhzhia Regional Council to ban the pro-Russian church, which blocked the process of its rapid consideration and adoption. Subsequently, the church publicly thanked and expressed support for the candidate. In May 2023, candidate was excluded from the Coordination Council and deprived of his powers, in particular, the right to conduct business correspondence on behalf of the Zaporizhzhia Regional Council, to put his signature on official forms, etc.

The media also reported that Podorozhko appeared in a criminal case regarding the purchase of a generator for a Zaporizhzhia school at a threefold inflated price.

Our questions to the candidate

1. Was Podorozhko really appointed on the recommendation of the currently banned pro-Russian Opposition Bloc party? If so, how can he explain this and does he maintain contact (formal or informal) with persons associated with the party now?
2. What is the candidate’s connection with the UOC-MP?
3. How can Podorozhko explain his participation in the case of purchasing a generator for a school in Zaporizhzhia?
4. What is the candidate’s attitude to the events around the then head of the Zaporizhzhia Regional State Administration Kostiantyn Bryl?

Roman Romaniuk

Education: two higher educations; Lutsk State Technical University, Finance; Lesya Ukrainka Eastern European National University, Law.

Position: Head of the Secretariat of the Human Rights Commissioner of the Verkhovna Rada of Ukraine, associate professor of the Department of Personnel Management, Labor Economics and Public Administration of the North-Ukrainian Institute of the Interregional Academy of Personnel Management, senior lecturer of the Lesya Ukrainka Economics and Trade Department of the Volyn National University, Candidate of Economic Sciences.

Since September 2023, studies at Taras Shevchenko National University of Kyiv, Educational and Scientific Institute of Public Administration and Civil Service, specialty Public Governance and Administration.

Employment and property

Before becoming the Head of the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine, he was the Director of the Volyn Regional Employment Center for 5 years.

During 2010-2018, he was a member of several parties – “For Ukraine,” “Front of Change”, and Bloc of Petro Poroshenko “Solidarity.”

In 2010-2015, he was a member of the Lutsk City Council of the 6th convocation from the political party “For Ukraine!” In 2015-2017, he was a member of the executive committee of the Lutsk City Council, and in 2014-2016, he was a member of the public council under the head of the Volyn Regional State Administration.

In the local elections of 2015, he ran for the Lutsk City Council on Solidarity lists, but did not get enough votes. Later in 2020, he ran for the Volyn Regional Council from the Servant of the People party, but was unsuccessful.

For 2022, the candidate declared an apartment in Lutsk with an area of 129 m2, 7 land plots owned by his wife, and 2 cars. He is renting an apartment in Kyiv. For 2022, Romaniuk received a total of UAH 1.4 mln in salary. He keeps USD 30,000; UAH 300,000; and EUR 10,000 in cash.

Our questions to the candidate

1. What is the source of the declared cash?
2. Where did the candidate’s wife get the money to acquire 7 plots of land? Did the professional activity of the candidate in the city council contribute to his wife’s acquisition of land plots?
3. Does he keep in touch with any of the representatives of the political parties he was a member of?

Oleksandr Skomarov

Education: From 2005 to 2008, he studied at E. Didorenko Luhansk State University of Internal Affairs, having received a bachelor’s degree in law, with honors. From 2008 to 2010, he studied at the National Academy of the Prosecutor’s Office of Ukraine, upon completion of which he received a master’s degree in the specialty Law, with honors.

Position: Deputy Head of the Main Detective Unit — Head of the Second Detective Unit of the Main Detective Unit of the NABU.

Employment and property

In 2010, he started working in the prosecutor’s office of Luhansk Oblast as an intern and later as an assistant prosecutor. In 2012, he held the position of prosecutor in Luhansk Oblast. At the beginning of 2015, he entered the postgraduate program of the National Academy of the Prosecutor’s Office of Ukraine, he is a candidate of sciences. Next year, he undergoes a competitive selection for the position of a NABU detective.  He holds the position of a senior detective, later the head of the detective department, later the deputy head of the detective division, and from since, the deputy head of the main detective unit.

He is a NABU detective in a number of high-profile cases, in particular, in the case of Rosenblatt, PrivatBank, MP Hunko, etc. Skomarov commented on the investigation into the embezzlement and seizure of property and funds of PJSC Ukrnafta in the amount of more than UAH 13.3 bln, regarding the seizure of funds of the state-owned enterprise Ukraine Printing Plant in the amount of more than UAH 450 mln, regarding the case of embezzlement of gas for UAH 2.1 bln, regarding the mechanism of illegal acquisition of assets with funds of the local budget and land of the territorial community of the city of Odesa, which caused UAH 689 mln losses, investigation of facts of corruption at state enterprises, institutions, and organizations of the National Academy of Agrarian Sciences of Ukraine. He also gave an interview in the Secrets of the NABU series of materials regarding the investigation of the Privatbank case (regarding the withdrawal of funds from it before nationalization).

He is a candidate of legal sciences, applied for a number of competitions, including director of the NABU and head of the SAPO.
The candidate underwent recusals due to the non-admission of the assistant lawyer to review the case materials with the consent and together with the lawyer and the suspect.

In October 2022, the candidate’s wife purchased a second car for UAH 400,000. However, on average, an Outlander car costs UAH 500,000 or more.

In 2018, he bought a new Ford Fusion with a declared value of UAH 121,338, which at the official rate of the NBU is USD 4,315. According to the popular American car sales resource, the cost of such a car as of today is approximately USD 17,000.

Our questions to the candidate

1. Has Skomarov visited the temporarily occupied territories? Does the candidate maintain his connection with real estate in Luhansk Oblast?
2. Why is the value of cars lower than the market value?
3. Can the candidate explain the situation where the lawyer’s assistant was not allowed to review the case materials?
4. Does his professional activity overlap with the professional activity of his wife? Is it true that until 2021, the candidate’s wife worked at Plus TV LLC, owned by Kolomoiskyi’s business partner Timur Mindich, while the candidate himself participated in the investigation of the Privatbank case?
5. Why did the candidate decide, after participating in competitions for the heads of the SAPO and the NABU, to apply for the position of the head of a preventive body?
6. Does the candidate currently have connections with politicians or government officials?

Oleksandr Starodubtsev

Education: 1996 – 2002 – National Technical University Kharkiv Polytechnic Institute. Financial management, specialist; 2006 – 2007 – Kyiv-Mohyla Business School; 2017-2018 – Stanford University, California, Visiting Fellow.

Position: Deputy Chief of Staff of the National Agency on Corruption Prevention.

Employment

Until 2015, he worked in the private sector.

From April 2015 to August 2017, he worked as the director of the public procurement regulation department of the Ministry of Economic Development and Trade of Ukraine. He was involved in the creation of ProZorro.

From September 2017 to June 2018, he studied at Stanford University (California), as a visiting fellow. Oleksandr Starodubtsev was one of the first participants in the program Ukrainian Emerging Leaders Program of Stanford University (USA).

From November 2019 to March 2020, he headed the National Agency for Civil Service.

On May 12, 2020, he was appointed to the position of Deputy Head of the NACP, since May 2022 — Deputy Chief of Staff of the NACP, where he is responsible for the coordination of HR, digital transformation, and educational work.

He is a co-founder of the civic platform New Country and the educational initiative Open University of the Maidan.

Our questions to the candidate

1. What did Starodubtsev do in order to solve the issue of significant staff turnover and unfilled vacancies at the NACP?
   How does he plan to solve this in the future?
2. Does the candidate think that an open competition should be introduced for the positions of Deputy Head of the NACP? Did all the ideas of the candidate during his work at the NACP find feedback from their executors and were they implemented?
3. What does the candidate think about the fact that he worked for a long time during the full-scale war as the deputy head of an official who was a member of the Party of Regions and worked in a leadership position in the Ministry of Family, Youth and Sports of Ukraine, the State Service of Youth and Sports of Ukraine, the Ministry of Youth and sports of Ukraine during the entire period of Yanukovych’s regime? Does the candidate know about any recent scandals surrounding these government departments? Is it ethical for such an official, who ran for MPs on the list of the Party of Regions in the 2006 elections, to continue to remain in one of the senior positions in the NACP under the new leadership?
4. What has Starodubtsev done in the last almost 4 years of work at the NACP to solve the problem outlined by the candidate in the motivation letter of “inadequate interaction of the NACP with stakeholders for progress in all directions/dimensions, primarily with civil society”?
5. Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them? Is Starodubtsev as Deputy Chief of Staff aware of any steps taken by the NACP to develop an Implementation Plan for the Recommendations of this audit, especially from Chapter 9 on the management and organizational capacity of the Agency, the area in which the Evaluation Commission found the highest level of non-compliance with the NACP’s evaluation criteria — 48%?
6. Does Starodubtsev support the new sanctioning direction of the Agency’s work, despite the fact that it is not provided for in the specialized law? Does he consider it relevant to the task and purpose of the NACP?
7. In the motivational letter, the candidate mentions the necessary automation of processes in the NACP. Does Starodubtsev support the automation of full checks, which was recently introducedby the Agency, despite the conclusions set out in the report of the first independent audit of the NACP?
8. How exactly can the Corruption Perceptions Index serve as one of the main measures of success in solving challenges in the anti-corruption field? Is the candidate familiar with the methodology of the Corruption Perceptions Index? (question based on the motivation letter)
9. Is Starodubtsev aware of negative assessments from stakeholders regarding his presidency of the National Civil Service Agency? What is the relationship of the candidate with the current leadership of the National Civil Service Agency after his dismissal? Does he know about the reason for his dismissal from the position of the Head of the National Civil Service Agency? Why did the candidate lose the post of Deputy Head of the NACP? Does the candidate know about negative assessments from stakeholders regarding his work at the NACP, the implementation of the presented activity plans, etc.?
10. Since 2016, the candidate’s wife, Olena Starodubtseva, has been working at Prozorro State Enterprise, which is under the Ministry of Economy. The candidate also worked there in the same period, as the director of the public procurement regulation department of the Ministry of Economic Development and Trade of Ukraine. Was there no conflict of interest in this?
11. In the declaration for 2023, the candidate indicates that the daughter has been living in a room in the Netherlands since January 2023. On what basis does she live there (rent/ free accommodation)?

Serhii Stepanian

Education: Yaroslav Mudryi National Law Academy

Position: Acting Director of the Department for Detection and Prevention of Corruption of the Ministry of Defense of Ukraine

Employment

Since 1999, he worked in the prosecutor’s office in Sumy Oblast in various positions.
The last position he held was the prosecutor of the SAPO of the Prosecutor General’s Office. In connection with the mobilization to the Armed Forces, he was released from the duties of a prosecutor; since February 24, 2022, he was mobilized to the ranks of the Armed Forces and is a participant in hostilities.

In March 2023, he was appointed to the position of Deputy Director, Head of the Anti-corruption Legislation Control Department of the newly created Department for the Prevention and Detection of Corruption of the Ministry of Defense of Ukraine.  After that, he immediately became the acting director of the Department and is still in this position.

Since joining the Ministry of Defense, he has communicated with the media about scandalous procurement. He participated in educational events for students.

Our questions to the candidate

1. After being appointed to a position in the Ministry of Defense, he said on 15.03.2023 that “the Ministry of Defense sees closer interaction with the public as one of the elements of work at the systemic level.” How does it manifest itself, and what are its results?
2. How can he comment on his communication regarding the procurement scandals of the Ministry of Defense and the scandals themselves? How can Stepanian comment on the activity of investigative journalists and the anti-corruption council under the Ministry of Defense in procurement scandals? How does the candidate feel about the persecution of journalists for exposing procurement scandals? Whicj achievements can the candidate name during his work at the Ministry of Defense?
3. In the opinion of Stepanian, is it ethical for an official to remain in the status of interim manager for a long time, for example almost a year or more? Should such a practice be spread and recognized as integrity-based?
4. Why does the wife not receive dividends from a 50% share in the authorized capital of the travel agency?
5. What does the candidate think of the draft law approved by MPs, but not signed by the President 9587-d , which concerned changes in the work of the Register of Corrupt Officials? Was it necessary to veto it?
6. Does Stepanian provide or arrange for appropriate advisory support in filling out declarations for colleagues at his workplace? Does he provide informative explanations of the provisions and requirements of anti-corruption legislation to colleagues, especially in non-standard situations? Do the candidate’s colleagues have all the necessary information regarding compliance with the requirements of anti-corruption legislation?
7. Why didn’t Stepanian declare expenses and transactions, on the basis of which he had the right to use, including joint ownership, movable property in 2019?
8. Why didn’t the candidate indicate in the declarations for 2015, 2016 and 2018 real estate belonging to his family members (sons Timur and Damir Podloznyis) on the right of ownership, are the objects on lease or on another right of use?
9. In the declaration for 2020, the candidate declared real estate objects that he had on other right of use: a residential building in Sumy with a total area of 162.9 square meters with the date of acquisition of the right 31.08.2010, and a land plot in Sumy with a total area of 633 square meters with the date of acquisition of the right 27.07.2012. Why is there no information about the specified real estate in the declaration for 2015?
10. In the declaration for 2020, the candidate declared another right of use — driving a Renault Koleos car with the date of acquisition of the right 14.04.2010 and Nissan Qashqai with 12.04.2008 as the date of acquisition of the right. Why is the declaration for 2015 lacking the information on the rights of use for the specified valuable movable property?
11. How were the corporate rights of PE MIK transferred to the ownership by your wife Iryna Podlozna to the new owner Inna Burlata? If it were a sale, why was no income from the alienation of corporate rights declared in 2019?

Andrii Teteruk

Education: In 1994, he graduated from the Moscow Higher Military Command College, after which he served five years in the Armed Forces of the Russian Federation under contract. In 2011, he graduated from the Vinnytsia Institute of Trade and Economics of the Kyiv National University of Trade and Economics, majoring in organization management.

Position: From September 2023, the head of the risk analysis department of the NACP of the Department of Integrity Policy Formation in the Security and Defense Sector.

Employment and property

Prior to a position in the NACP, he was MP of Ukraine of the 8th convocation from the People’s Front (2014–2019). He is a participant in the anti-terrorist operation, commander of the volunteer battalion of the special police patrol service “Peacemaker” of the Ministry of Internal Affairs of Ukraine in Kyiv Oblast.

The candidate voted for the adoption of legislative changes regarding the discriminatory distribution of electronic declaration to anti-corruption public activists, which was later recognized as unconstitutional by the CCU. During his tenure as MP, he appeared, in particular, in the scandalsrelated to assaulting colleagues in the parliament.

In 2016, the candidate filed a lawsuit against Gravis-Kino LLC for the protection of honor, dignity and business reputation, refutation of inaccurate information. At the same time, he also requested to collect moral damages, while the legislation limits such right of entities of power as plaintiffs in the relevant category of cases. The court partially upheld the claim.

In 2017, he took part in a court hearing where the issue of selecting an interim measure for the then deputy mayor of Irpin, Dmytro Khrystiuk, who was suspected of embezzling budget funds, was considered, and expressed his desire to take the latter on bail.

In 2019, the NACP appealed to the court to bring Teteruk to administrative responsibility for violating the requirements of the law on the prevention and settlement of conflicts of interest. According to the protocol, the candidate, being an MP of Ukraine, took actions in the conditions of a real conflict of interests. The court closed the proceedings in the absence of an administrative offense.

He was a candidate for MP from the “Ukrainian Strategy of Groisman” party in the 2019 parliamentary elections, No. 8 on the list.

In 2020, Teteruk appealed to the court with a claim to the Main Directorate of the Pension Fund of Ukraine in the Kyiv region regarding the recognition of the inaction, which consisted in limiting the pension, as illegal, and the obligation to carry out its recalculation. The court partially upheld the claim, as the candidate had formulated the claims incorrectly.

Our questions to the candidate

1. Why didn’t Teteruk information about his work from 2019 to 2023 in his autobiography? Was the candidate at that time in labor or other contractual relations with a political party? Does the candidate maintain political ties with individuals or parties?
2. According to the declaration for 2016, the candidate’s assets increased by UAH 150,000. But for this year, the candidate declared a total income of UAH 180,000. How did the candidate support a family of 4 people, including 2 minor children (one of the candidate’s sons, a student, according to the declaration, received a total of UAH 13,000 of income for the year) and a wife who received no income in 2016? Was UAH 30,000 really enough for the year?
3. Why did the candidate stop declaring the 2007 Ford Fusion since 2016?
4. On the basis of what does the candidate own land plots in the village of Khotianivka of the Vyshhorod district of the Kyiv region?
5. What are the main achievements of the candidate in the position of head of the risk analysis department of the Department of integrity policy formation in the field of security and defense of the NACP?
6. Were there any conflicts when working at the NACP in view of the Agency’s appeal to the court in 2019 to bring Teteruk to administrative responsibility for violating the requirements of the law on the prevention and settlement of conflicts of interest? Will this not affect the attitude towards subordinates (or some of them) in the future in case of appointment to the position of the Head of the NACP?
7. Why did Teteruk, as MP, vote for the extension of e-declaration to anti-corruption activists? Does he consider such a law justified and does he not see in it disproportionate restrictions on the activities of public figures?
8. Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them?
9. Does he support the new sanctions direction of the Agency’s work, despite the fact that it is not provided for in the specialized law? Does he consider it relevant to the task and purpose of the NACP?

Artem Khavanov

Education: Taras Shevchenko National University of Kyiv, complete higher education in the specialty Legal Studies; Higher educational institution KROK University of Economics and Law, Postgraduate course, specialty Economic security of the state

Position: Commissioner for anti-corruption activities at JSC State Export-Import Bank of Ukraine

Employment

From 2010 to 2017, he worked at JSC UkrSibbank BNP Paribas Group as a leading specialist, group leader, senior compliance manager for compliance with sanctions and embargoes. From 2017 to 2020, he headed the Anti-Corruption Program at Naftogaz Group. In 2020, he was the head of the compliance office at State Concern UkrOboronProm.

Prior to his current position, Khavanov worked for 2 years as the head of the anti-fraud department at METINVEST HOLDING LLC.

In 2018, the candidate drove a car while intoxicated. The examination of the state of intoxication was carried out in accordance with the procedure established by law, the result was 0.57% ppm. The candidate partially pleaded guilty, the court imposed a fine of UAH 10,200, with the deprivation of the right to drive vehicles for a period of 1 year.

Our questions to the candidate

1. How can khavanov comment on his driving while intoxicated?
2. What is the candidate’s attitude to the scandal at JSC State Export-Import Bank of Ukraine related to the attack on investigative journalists?
3. How does Khavanov assess the current level of regulation by the NACP of the lifestyle monitoring procedure and the functioning of the Unified Whistleblower’s Reporting Portal? (question based on motivation letter)

Ivan Yuriichuk

Education: 1996-2001 – Vasyl Stefanyk Prykarpattia University (Ivano-Frankivsk), specialty Physics.
2016-2019 – National Academy of Public Administration under the President of Ukraine (Kyiv), specialty Public Governance and Administration

Position: Deputy Head of the State Education Quality Service of Ukraine for issues of digital development, digital transformations and digitalization

Employment

Yuriichuk began his professional career as a physics teacher, then worked in the Department of Education and was an assistant consultant to MP of Ukraine for several months. From 2015 to 2018, he worked at the State Inspectorate of Educational Institutions of Ukraine, since 2018 he has been working at the State Education Quality Service of Ukraine, at first he worked as the director of the accreditation and monitoring department.

He is also engaged in teaching activities and is a senior lecturer at the Department of Management at Borys Hrinchenko University of Kyiv.

Our questions to the candidate

1. Why did Yuriichuk decide to change the field of activity?
2. What does the candidate consider to be the main problems of the NACP at the moment and which ways of their solution does he see? Did the candidate get acquainted with the conclusions set out in the report on the results of the independent assessment of the National Agency on Corruption Prevention for 2020-2021? Does he agree with them?
3. Yuriichuk indicates that from 2010 to 2012, he was a member of the All-Ukrainian Union Freedom political party, did he run for office in any elections?
4. Was the candidate a member of the PETRO POROSHENKO BLOC political party in 2014?
   If so, why did he decide not to mention it in his autobiography?
5. From 01.04.2015 to 11.06.2015, Yuriichuk was an assistant consultant to MP of Ukraine. Who exactly did the candidate cooperate with? On which issues did he provide consultations, and which political force did the MP represent?
6. Does he now have connections with politicians or government officials?
7. In the Unified State Register of Court decisions, there is a 2012 decision on bringing a candidate to administrative responsibility under 173 of the Code of Administrative Offenses. The proceedings in the case were closed due to the absence of an administrative offense. What were the circumstances of the attempt to bring the candidate to administrative responsibility?
8. If Yuriichuk is appointed to the position of the head of the NACP, does he plan to continue teaching at the university?
9. Did he conduct dissertation research? What was his topic, and did he already defend his thesis?
10. Is Yuriichuk secretary general of the NGO United Media Union? If so, does this position belong to the governing, auditing, or supervisory bodies of the NGO?
    Is he a member of this NGO?