6.1. We recommend indicating in the section of the Compliance Policy concerning Ukraine that the value of a gift that can be given by Company X employees to any representatives of the public sector cannot exceed 50 percent of the minimal wage as of the day on which the gift was accepted in UAH (or its USD equivalent according to the official UAH/USD exchange rate of the National Bank of Ukraine). Because both, the amount of the minimal wage and the official UAH/USD exchange rate of the National Bank of Ukraine, change from time to time, the Compliance Policy should indicate that these indicators should be checked by the Company X employees before presenting the gift.

6.2. In our opinion, in defining the public sector for the purposes of identifying corruption acts one should proceed on the basis of a list of persons that are authorized to perform the responsibilities of the State or local self-governed bodies and the persons that are regarded as being vested with such responsibilities. We would recommend providing the list of persons, as stated in section 2.2. (clauses 2.2.1-2.2.4).

6.3. In the section of the Compliance Policyconcerning Ukrainewe recommend including a provision which stipulates that individuals and legal entities are not allowed to finance public authorities or local self-governed bodies, to grant them material and/or intangible assistance, to perform works free of charge, to render services free of charge, to transfer means or other property (except for the cases stipulated by the laws and the effective international treaties of Ukraine made in compliance with the procedure prescribed by law). In our opinion, these legal provisions prevent financing of trips of persons working in the public sector and financing the accompanying services.