Since anticorruption regulations in Belarus are currently underdeveloped and often the distinction between a disciplinary and administrative offence or a crime is vague we highly recommend developing and implementing a detailed anticorruption corporate policy with assistance of qualified legal practitioners acquainted with local practice.

Such policy may incorporate the following cornerstone provisions:

• Corporate anticorruption policy should be binding for all company’s employees without exception;
• Corporate anticorruption policy should describe in detail the list of persons subject to anticorruption regulations, including all of the Officials, Public Officials, Government Officials and Individuals having the Same Status as Public Officials, as denoted herein. For the purposes of effectiveness of such policy it is important to cover any position which vests relevant officer with specific authority and/or official duties that may be exercised in respect of individuals and legal entities not subordinated to such an officer.
• Corporate anticorruption policy should directly and strictly oblige employees to inform their senior management about making any gift or providing any benefit to any Public Official or Official;
• Gifts (including services) as a general rule could be granted to  Officials only during ceremonial, protocol or other official events. However such gifts (including services) would be seized and transferred for the benefit of the State of Belarus in case where their value exceeds 5 basic units (currently about USD $58). Since both the basic amount and the official BYR/USD exchange rate set by the National Bank of the Republic of Belarus change from time to time – corporate anticorruption compliance policy should instruct the personnel to double-check the figures before granting and receiving any gift;   
• It is highly recommended at all times to avoid creating the perception that the purpose of any  gift giving may be connected to the exercise of an Official’s authority and/or duty for the benefit of the gift-giver and/or of the company.

Corporate anticorruption policy should specify that the company and its employees are not allowed to finance Public Officials/Officials, grant them whatsoever material and/or intangible assistance, perform works free of charge, and render services free of charge (except otherwise expressly provided by Belarusian laws, e.g. reimbursement of travel and accommodation costs during certification and testing procedures).