Introduction

MISSION KHARKIV is committed to ensuring integrity, transparency and full compliance with all applicable laws and regulations, including those related to combating money laundering, fraud and terrorist financing (AML/CFT).

MISSION KHARKIV understands and takes a responsible attitude to issues related to the prevention of money laundering and fraud, realizing the importance of this issue in the context of military aggression and Ukraine's being at war.

The Statement defines the position, obligations, and approaches to preventing money laundering and terrorist financing of the CO Charitable Foundation "MISSION KHARKIV" (hereinafter referred to as the Foundation).
The Foundation is committed to conducting its activities in a manner that prevents any involvement in money laundering, fraud or terrorist financing. By implementing robust anti-money laundering measures and developing a culture of compliance, the Foundation seeks to protect the organization, beneficiaries and donors of the Foundation, as well as to contribute to global efforts to combat money laundering and terrorist financing.

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Political Statement

MISSION KHARKIV strictly prohibits the activities or use of the Foundation's infrastructure for any form of money laundering, fraud or terrorist financing. The Foundation, represented by its employees, partners, volunteers, beneficiaries and donors, takes the obligation to prevent, detect and report any suspicious activities very seriously and responsibly

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APPROACH TO MONEY LAUNDERING AND THE PREVENTION OF FRAUD AND TERRORIST FINANCING

I. RISK ASSESSMENT:

We conduct regular risk assessments to understand and manage our exposure to money laundering, fraud and terrorist financing. We place great importance on understanding the risks that may arise from our interactions with donors, beneficiaries, locations of operation and the nature of our programs.
Identifying, understanding and assessing risks is a fundamental step in creating an effective system to combat money laundering and fraud and take measures to mitigate their impact.

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Personnel

The main responsibility for risk assessment lies with the volunteers and/or employees of the Foundation who are anti-money laundering officers (AMLOs), acting on the basis of separate contracts or appointed by the Director.
The AMLO should have sufficient knowledge and experience to understand and manage the money laundering risks not only in Ukraine but also in the countries of origin of donors, and should be empowered to implement the necessary changes. AMLO works in coordination with the Chief Financial Officer (CFO), Chief Accountant, Program Directors, and Field Coordinators to ensure that risks are understood.

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Regular reviews and risk identification

At least once a year or whenever there are changes in the Foundation's activities, donors, beneficiaries or operating environment, checks are carried out to determine whether there are anymoney laundering, anti-fraud and counter-terrorist financing risks and to update the understanding of the existence/absence of such risks.

The risk identification process includes an assessment of various risk factors, such as:
- Geographical risks: certain countries or regions may pose a higher risk of money laundering, for example, countries or regions with high levels of corruption or weak AML/CFT regulations.
- Donor risks: Some donors may pose a greater risk, such as those who wish to remain anonymous, those who make extremely large donations, or those based in high-risk countries.
- Program risks: Some of our programs may be more susceptible to money laundering risks than others, such as those that involve large financial transactions or cash payments.
- Delivery channel risks: Certain delivery channels may pose a greater risk, such as those that involve third parties or non-face-to-face interactions.

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Mitigating risks

Once risks are identified, appropriate mitigation measures are taken. This may include enhanced due diligence for high-risk donors, additional financial controls for high-risk programs, or additional training for staff working in high-risk environments.

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II. Internal controls and procedures:

MISSION KHARKIV has implemented robust internal controls and procedures to prevent, detect and respond to money laundering risks. These controls are designed to ensure that all our actions comply with our anti-money laundering policy and the provisions of applicable law, and are transparent and understandable to our donors and beneficiaries.

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Personnel

The AMLO is responsible for overseeing the implementation and effectiveness of our internal controls and procedures. AMLO is supported by a Chief Financial Officer who ensures that financial controls are in place and operating effectively. Program directors, field coordinators and other key staff also play an important role in implementing these controls within their respective areas of responsibility.

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Key controls and procedures

1. Financial Controls: We have established financial controls to monitor all financial transactions and identify any suspicious activity. These controls include segregation of duties, approval processes for major transactions, regular financial reviews, and clear documentation practices.
2. Know Your Donor (KYC) procedures: We conduct due diligence on all donors to ensure that we understand the source of their funds and to identify any potential money laundering risks. This includes verifying the identity of the donor, checking against any sanctions lists, and understanding the nature of the donor's business or activities.
3. Monitoring and Reporting System: We have implemented a system to monitor our operations for any signs of money laundering. Any suspicious activity should be reported immediately to the AMLO, who will then take appropriate action. All reports are documented and retained in accordance with our record keeping procedures.
4. Due diligence of partners: We conduct due diligence on all our partners, including suppliers and implementing partners, to ensure that they also comply with our anti-money laundering policies. This includes understanding their anti-money laundering policies and practices, and monitoring their activities for any suspicious behavior.
5. Regular reviews: Our internal controls and procedures are regularly reviewed to ensure that they remain effective and up-to-date. Any necessary changes are implemented under the supervision of the AMLO and the CFO.

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III. COMPLIANCE WITH LAWS AND REGULATIONS.

We will ensure compliance with all relevant anti-money laundering laws and regulations, including international standards, Ukrainian laws and the laws of any other countries in which we operate.

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IV. REPORTING:

Reporting suspicions of money laundering, fraud, and terrorist financing is a key responsibility of all employees of MISSION KHARKIV. The Foundation develops and establishes, implements and enforces clear procedures to ensure prompt reporting of all suspicious activities, the facts of their internal investigation and, if necessary, notification of the relevant authorities.

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IV. REPORTING:
reporting suspicious activity

1. Identification:

All employees are familiar with and understand the steps involved in identifying potential indicators of money laundering, fraud and terrorist financing. This may include unusual financial transactions, donors who are reluctant to provide information, or suspicious behavior by our partners or beneficiaries. All agreements, contracts with donors, beneficiaries have certificates, warnings about the impossibility of relations with persons involved in money laundering, terrorist financing, in accordance with the current legislation of Ukraine, have assurances regarding the implementation of the Law of Ukraine "On the Basic Principles of Forced Seizure of Property of the Russian Federation and its Residents in Ukraine" dated March 3, 2022 No. 2116-IX and the Resolution of the Cabinet of Ministers of Ukraine "On Ensuring the Protection of National Interests in Future Claims of the State of Ukraine in connection with the military aggression of the Russian Federation" No. 187 dated March 3, 2022, CONFIRMATION OF THE ABSENCE OF ANY FACTORS/CIRCUMSTANCES OF RELATIONSHIP WITH THE AGGRESSOR STATE (Russian Federation), in particular, the presence among the ultimate beneficial owners, members or participants (shareholders) having a share in the authorized capital of 10 percent or more, among the Parties to any economic relations, the absence of the Russian Federation, citizens of the Russian Federation, or legal entities established and registered in accordance with the laws of the Russian Federation.

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2. Immediate Reporting

Any employee who becomes aware of potential money laundering activity must immediately report it to their supervisor or directly to the Anti-Money Laundering Officer (AMLO). This report should include all relevant details and be documented in writing.

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3. Investigation

Upon receipt of a report, the AMLO will conduct an initial investigation to assess the seriousness and credibility of the report, including by conducting additional interviews, reviewing financial records, or consulting with other employees or external experts.

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4. Reporting to authorities

If the AMLO determines that the report is credible and constitutes a potential violation of money laundering legislation, they will report it to the relevant Ukrainian authorities. In Ukraine, this is usually the State Financial Monitoring Service, which is responsible for combating money laundering and terrorist financing.

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5. Confidentiality

All suspicious activity reports are treated with the highest level of confidentiality. The identity of the reporting employee will be protected to the fullest extent possible and any retaliation against reporting employees will not be tolerated.

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6 Record keeping

All reports and investigations are documented and retained for a minimum of five years in accordance with Ukrainian law and international best practice.

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V. AWARENESS RAISING AND TRAINING:

We conduct regular training and awareness programs for all of our employees to ensure that they understand their responsibilities and are able to identify and report any suspicious activity.

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VI: PARTNERSHIP:

MISSION KHARKIV expects all our partners, including donors, suppliers and implementing partners, to comply with our anti-money laundering policy, and we conduct due diligence on our partners and monitor their activities to ensure compliance with anti-money laundering, anti-fraud and counter-terrorist financing requirements.