COMPLAINT 201902054 20191111 115631 Redacted.pdf

to facilitate corruption, for instance by not doing enough to stop corrupt money being siphoned off to EU.
December 5, 2016, in accordance with Article 90 of Staff Regulations No 31 (EEC), 11 (EAEC), I have submitted by
letter to the Ministry of Foreign Affairs of Denmark as to the appointing authority for EU Anti-Corruption Initiative in
Ukraine 2017-2019 (ENI/2016/039-504) and asked him to inform me about all reasoned decision in regard to me. But
up until now nobody from Ministry of Foreign Affairs of Denmark hasn’t responded to me.
By 19 February 2017 I provided The European Anti-Fraud Office (OLAF) with information about potential violations of
the EU Staff Regulations and corruption within European Commission on the case of acquisition IISW by Metinvest,
SKM and Energees. But by 15 May 2017 OLAF has dismissed the case on the grounds that there is no sufficient
suspicion to open an investigation.
On the basis of the above, I have reason to believe that:
1. Appointing authority for EU Anti-Corruption Initiative in Ukraine 2017-2019 (ENI/2016/039-504) violated the ANNEX
III Competition of Staff Regulations No 31 (EEC), 11 (EAEC). For my opinion, procedure for recruiting was imitated or
falsified by
Mercuri Urval A/S - Denmark Ms.

and by Senior adviser Ministry of
Foreign Affairs of Denmark Ms.
As result, Kiev’s staff was accomplished by “anti-corruption
experts”, suitable mainly for Vice Prime Minister of Ukraine Ivanna Klympush-Tsintsadze, known as protégé of
Ukrainians oligarchs
and
Vacancy DK-01910-2016/UKR.03-W – Senior Anti-
Corruption Expert was illegally transferred to former member of the Lithuanian delegation for GRECO
who is directly responsible for ignoring money laundering going through Danske Bank in Estonia, Latvia
and Lithuania. As is generally known, former Ukrainian President Viktor Yanukovich stole nearly $1.5bn from the
country. According to The verdict of the Kramatorsk City Court from 28 March 2017 , ICU brokered the purchase of
dollar-denominated bonds on behalf of eight Cypriot companies. Everything was done via Latvian PrivatBank, Latvian
Baltic International Bank, Estonian Versobank, and the local branch of Danske Bank.
2. As estimated Chatham House, the Royal Institute of International Affairs( “Are Ukraine’s Anti-corruption Reforms
Working?” Research Paper
and
, Russia and Eurasia Programme | November 2018)
EU Anti-Corruption Initiative in Ukraine 2017-2019 targeted not just underlying causes of corruption but only
symptoms. “The present reality is that at some levels in international agencies and donor governments, including in
their embassies in Kyiv, there is sometimes only fragmentary understanding of the problem.”
3. Neither The Minister of Foreign Affairs of Denmark Mr. Kristian Jensen nor
Support Group for
Ukraine of the European Commission Mr.
informed the European Anti-Fraud Office (OLAF) about the
facts of corruption within European Commission on the case of acquisition IISW by Metinvest, SKM and Energees,
reported by me, and that is violation of Article 22a of Staff Regulations No 31 (EEC), 11 (EAEC).
4. European Anti-Fraud Office OLAF dismissed the case 2OLAF-OC20170347 because of a conflict of interest, since
Director-General of the European Anti-Fraud Office (OLAF) Mr Giovanni Kessler personally participated in the
organization Anti-Corruption Initiative in Ukraine 2017-2019 (ENI/2016/039-504)
5. Ministry of Foreign Affairs of Denmark groundlessly attracted private company Mercuri Urval A/S - Denmark for
participation in the process of appointment Anti-Corruption Staff, because created pre-conditions for leaking database
about anti-corruption experts and their families. Personally for me such leaking can be fatal, because my knowledge
touch interests of influential persons.
6. European Commission violated the statement of paragraph 5(a) of Article 3 Council Regulation (EC) No 139/2004
of 20 January 2004 on the control of concentrations between undertakings (the EC Merger Regulation) because
sending notification of a proposed concentration to European Commission Metinvest BV hasn’t received the consent
of bondholders to violate covenants. Commission also ignored facts that before purchase IISW’s shares Metinvest BV
actively applied anti-competitive action on purpose to deprive IISW on supplying with cheap raw materials. In October
2006 I conducted journalistic investigation on these facts and published materials in the weekly “The Island (Остров)”
(№35, 04/10/2006, p.9). Now Metinvest BV listed $2.2 billion in worldwide unpaid debt, including $ 1.1 billion in three
series of Eurobond notes and $ 1.1 billion in pre-export financing facilities. Only in 2012 Metinvest BV had paid $400
million in dividends for

7. Through European Capital market Metinvest BV has got illegally, for indefinite term, considerable financial
resources that has used for support Pro-Russian terrorists on Donbas. This support comes through the mechanism of
humanitarian help, while international humanitarian organization are shut out from Donbas.
8. Metinvest BV is the owner of United Coal Company (UCC) in U.S. since 2009. It owns 18 mines and is the sixth
largest metallurgical coal recovering company in U.S. Metinvest BV avoided default of his Eurobonds through
corruption and now supplied coal to Ukraine from U.S. mines for $71 per short ton. According to this scheme, money
is taken out of the Ukraine and transferred to the accounts of Metinvest’s own company in U.S., as profit.
Now I have reason to believe that my participation in the competition for vacancy DK-01910-2016/UKR.03-W – Senior
Anti-Corruption Expert, EU Anti-Corruption Initiative in Ukraine for the Danish Ministry of Foreign Affairs / Danida
became the reason for repression of my family in Poland. In addition, I received signs that my location in Europe is
wanted by the private security service, related to Ukrainian oligarch
In the current difficult circumstances I seek protection as potential whistleblower, in accordance with Directive of the
European Parliament and of the Council on the protection of persons who report breaches of Union law .
Sincerely

Attachment:
3

Part 9 - Please confirm that you have read the information below
You have read the information note on data processing and confidentiality
Part 10 - Do you agree that your complaint may be passed on to another institution or body
(European or national), if the European Ombudsman decides that he is not entitled to deal
with it?
Yes
5

Weekly “The Island”, Donetsk, Ukraine

For
Support
Group for Ukraine
Mr.

Dear Mr.

Long period of my professional career within Security Service of Ukraine I worked on
position of the  officer on question of crime  intelligence on fields   privatization and capital
market in Ukraine and abroad.  I had  been  watching directly all difficult and complicated
process of fighting for economics assets between political and business clans, application by
them different financial and legal tools. I will not make mistake, if I will say that these
processes considerably influenced on the European economy.
On the basis of   badly organized privatization of  post-soviet    public property there
raised  up great number of shadow assets, corrupting   economy of modern Europe. One of
their big priorities is getting  money into the West. They need to understand how  decision-
making works –  who makes the rules on money-laundering, who makes the rules on stock
exchange listings and who makes the rules on energy regulation. They want to know whether
they can change the rules, evade them or subvert them. I am sure, that these “hybrid” forms of
war on capital market was transformed in similar forms military activity.
I want to give an example on support my conclusions:
On 11/08/2010 the European Commission received a notification of a proposed
concentration by which Metinvest BV ("Metinvest", the Netherlands), controlled by SCM
holding ("SCM", Ukraine) and Energees Investment Limited ("Energees", Cyprus/Ukraine)
acquires within the meaning of Article3(1)(b) of the Merger Regulation sole control of CJSC
Ilyich Steel and OSC Ilyich Iron and Steel Works (both referred to as "IISW", Ukraine), by
way of purchase of shares.

After examination of the notification, the European Commission has concluded that
the notified operation  falls within the scope of the Merger Regulation and of paragraph 5(c)
of the Commission  Notice on a simplified procedure for treatment of certain concentrations
under Council Regulation (EC) No 139/2004.
As far as I know  Metinvest B.V. already offered  U.S.$500,000,000 10.25 per cent.
Guaranteed Notes due 2015 . Аgreement  dated on   20 May 2010 between the Issuer, the
Initial Guarantors and BNY Corporate Trustee Services Limited in its capacity as trustee,
Joint Bookrunners and Lead Managers wars : Credit Suisse, BNP PARIBAS, ING, The Royal
Bank of Scotland, VTB Capital.
Application has been made to the Irish Stock Exchange  to approve these listing
particulars and to admit the Notes to listing on the official list of the Irish Stock Exchange
and to trading on the Global Exchange Market of the Irish Stock Exchange.
Offering  memorandum contained  covenants restricting the ability of the Issuer and its
Subsidiaries to:
• borrow additional money;
• pay dividends, redeem or repurchase share capital or make other distributions;
• make principal payments on or redeem or repurchase indebtedness that is junior to the notes
or the guarantees;
• create liens;
• create restrictions on subsidiaries’ ability to pay dividends or other amounts to the Issuer;
• enter into transactions with affiliates;
• sell assets or consolidate or merge with or into other companies.
I also know that sending notification of a proposed concentration to European
Commission, Metinvest BV hasn’t received the consent of  bondholders to violate covenants.
I  think the Commission  wasn't entitled to consent   concentration on the simplified
procedure, since there were covenants in the investment memorandum of Metinvest BV, and I
suppose reasonably that Commission violated the  statement of Council Regulation (EC) No
139/2004 of 20 January 2004 on the control of concentrations between undertakings (the EC
Merger Regulation).  Commission also ignored facts that before purchase   IISW’s  shares
Metinvest BV  actively applied anti-competition action on purpose to deprive IISW on
supplying with cheap raw materials. In October 2006 I conducted journalistic investigation on
these facts and published materials in the weekly “The Island (Остров)” (№35, 04/10/2006,
p.9).

Far behind the scenes there are also facts of collaboration Metinvest BV with Iranian
authorities.
Metinvest BV is affiliated with  System Capital Management (SCM holding) owned
by
. According to the investment company Dragon  Capital the owner of the
SCM was called the richest man in Europe. As already known,
increasingly using
courts to redress alleged harms, punish journalists and scare off publishers,

I know for  certain, that activity on capital market such persons as

strongly irritates Washington, and that became especially actual in the light of armed conflict
in East Ukraine. In September 2015 I was invited in Washington D.C. where gave
consultation for American Foreign Policy Council and The International Republican Institute
on question of shadow activity on capital market in Europe, and I can confirm that
Washington is resolutely adjusted to change situation.
As I know, now Credit Suisse alongside Barclays, UBS and Deutsche Bank got the
problem related to ‘dark pool” and seriously probed by US regulators. As the result, Credit
Suisse and Deutsche Bank committed to provide strong risk culture with sophisticated and
independent risk management, compliance an control process. Supervisory intelligence staff
implemented now the new Compliance & Regulatory Affairs function “Signac” on base
Palantir’s software, which oversees the bank’s activities at all levels, with aims to prevent
high-profile financial scandals, such as the manipulation of interest and foreign exchange rate
benchmarks, dodge sanction and evade tax.
Nevertheless,  Deutsche Bank’s actions are now under investigation by the U.S.
Department of Justice, the New York State Department of Financial Services, and financial
regulators in the UK for mirror trade, using the stock market to send Russian money overseas.
I would like to underline, that basic problems   are    more related to political risks,
imposed by bank’s clients. I think that more productive will be maintaining Surveillance
system and up-to-date risk methodology for treatment of existing and prospective high-risk
clients.
I consider that the fight against these types of financial corruption crimes must be in
attention of European Commission.

With kind regards

OLAF.0.1 Investigation Selection & Review
Head of Unit
Mr.

e-mail:

Brussels
Subject:  Information on decision to dismiss a case
Case No OC/2017/0347 (Please include this number in all correspondence)
Dear Mr.
Thank you for your communication of 19 January 2017 and subsequent correspondence by
which  you  provided  OLAF  with  information  about  potential  violations  of  the  EU  Staff
Regulations1.
In accordance  with Regulation (EU, Euratom) No 883/2013,  OLAF's role is to protect the
financial interests of the EU by investigating fraud, corruption or other illegal activities. It
is also responsible for detecting and investigating serious matters relating to the discharge
of  professional  duties  by  members  and  staff  of  the  EU  institutions,  bodies,  offices  and
agencies that could result in disciplinary or criminal proceedings.
In  arriving  at  its  decision  whether  to  open  an  investigation,  OLAF  considers  whether  the
matter falls within one of the areas of investigative priority which are defined annually by
the Office and take into account principles of proportionality, subsidiarity/value added and
the efficient use of OLAF's resources.
OLAF has analysed the information received in accordance with Regulation (EU, Euratom)
No  883/2013  and  has  dismissed  the  case  on  the  grounds  that  there  is  no  sufficient
suspicion to open an investigation.
While  Article  302  of  the  Staff  Regulations  is  applicable  for  the  recruitment  of  offcials  to
work within the EU institutions, it is not applicable for recruitments of experts to take part
in  the  Anti-Corruption  Initative  in  Ukraine,  led  by  the  Ministery  of  Foreign  Affairs,
Denmark.
Moreover, the alleged market-manipulation or other anti-competition actions linked to the
METINVEST BV/IISE merger does not fall under OLAF’s comptence. Subsequently, there is
no obligation, under Article 22 of the Staff Regulations, for EU-staff to report such matter
1  Regulation  No  31  (EEC),  11  (EAEC)  laying  down  the  Staff  Regulation  of  Officials  and  the  Conditions  of
Employment  of  Other  Servants  of  the  European  Economic  community  and  the  European  Atomic  Energy
Community (Staff Regulation)
2 Title III Career of Officials, Chapter 1 Recruitment
OLAF  Rue Joseph II, 30  B-1049 Brussels (Belgium)  Tel: +32 (0)2 299 11 11  Web: http://ec europa eu/anti_fraud

to OLAF.
Your attention is drawn to the privacy statement below.
Yours sincerely,
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please be informed that your personal data are stored in OLAF’s electronic and paper files concerning this matter
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2

professional experience by 400 notes without spaces. In the letter I described the operational
environment in Ukraine  as the set of global conditions, influences and circumstances that
affect anti-corruption policy. Additionally I reported to The Minister certain facts about a
possible corruption within European Commission on the case of acquisition IISW by
Metinvest BV , SKM and Energees.
September 8, 2016 I took part in panel discussion Kiev Dialogue: “Wirtschaftliche
Stabilisierung und Korruptionsbekampfung in der Ukraine”, that was held in Berlin. During
this event I passed the letter to
Support Group for Ukraine of the European
Commission Mr.
in that reported him facts about a possible corruption within
European Commission on the case of acquisition IISW by Metinvest  BV, SKM and
Energees. Mr.
answered me by letter that doesn’t see the signs of corruption in
my report, however admits that serious failure to comply with the obligations of officials took
place, and suggested me to investigate this case by myself, without his participation.
November 16, 2016 I got the information from
  Mercuri Urval
A/S  -  Denmark Ms.

, that the Ministry of Foreign Affairs has finalized its
handling of the recruitment and selection process and has authorized Mercuri Urval to inform
me that the above position has been offered to another candidate. Ms.

notified
me, that the profile of the successful candidate has, to a higher degree, been assessed to meet
the demands for the position as drawn up in the job profile. The decision of the Danish
Ministry of Foreign Affairs, as she notified, was based on a number of factors including the
candidates' educational background and professional experience.
As is generally known, conditions of employment of officials and other servants of
the EU are regulated by Staff Regulations  No 31 (EEC), 11 (EAEC). Staff Regulations is the
official document describing the rules, principles and working conditions of the European
civil service. These rules are essential to guarantee the European civil service maintains the
highest standards.
In accordance with Article 30 Staff Regulations   No 31 (EEC), 11 (EAEC)  for each
competition, a selection board shall be appointed by the appointing authority. This board shall
draw up a list of suitable candidates. The appointing authority shall decide which of these
candidates to appoint to the vacant posts.
In my opinion, the private company Mercuri Urval A/S –  Denmark  is not the
appointing authority for EU Anti-Corruption Initiative in Ukraine 2017-2019 and I cannot

count the report of Ms.

as official opinion of the Selection board of the
appointing authority.
In Concept Note “Indirect Management of the EU Program Support to Combating
Corruption in Ukraine (2017-2019) implemented by Denmark”, issued by Ministry of Foreign
Affairs of Denmark, in part “Management arrangements” has been foreseen, that recruitment
of anti-corruption experts will be mostly from EU Member State anti-corruption institutions:
Romanian Anti-Corruption Agency, Danish Ombudsman function, Special Investigation
Service of Republic of Lithuania.
As is known,
a leading Ukrainian anti-corruption activist, who was
consulted for EU officials in preparation for implementation of the EUR  EU Anti-Corruption
Initiative in Ukraine 2017-2019, worried that large part of the EUR 16 million would be spent
on European “experts”.
has been vocal about how the EU has helped to facilitate
corruption, for instance by not doing enough to stop corrupt money being siphoned off to EU.
December 5, 2016, in accordance with Article 90 of Staff Regulations  No 31 (EEC),
11 (EAEC),  I have submitted by letter to the  Ministry of Foreign Affairs of Denmark as to
the appointing authority for EU Anti-Corruption Initiative in Ukraine 2017-2019
(ENI/2016/039-504) and asked him to inform me about all reasoned decision in regard to me.
But up until now nobody from Ministry of Foreign Affairs of Denmark hasn’t responded to
me.
By  19 February 2017 I provided  The European Anti-Fraud Office  (OLAF) with
information about potential violations of the EU Staff Regulations and corruption within
European Commission on the case of acquisition IISW by Metinvest, SKM and Energees.
But by 15 May 2017  OLAF has dismissed the case on the grounds that there is no sufficient
suspicion to open an investigation.

On the basis of the above, I have reason to believe that:
1.  Appointing authority for EU Anti-Corruption Initiative in Ukraine 2017-
2019 (ENI/2016/039-504) violated the ANNEX III Competition of Staff
Regulations   No 31 (EEC), 11 (EAEC).  For my opinion, procedure for
recruiting was imitated or falsified by
Mercuri Urval
A/S  -  Denmark Ms.

and by Senior adviser Ministry of
Foreign Affairs of Denmark Ms.
  As result, Kiev’s
staff was accomplished by “anti-corruption experts”, suitable mainly for
Vice Prime Minister of Ukraine Ivanna Klympush-Tsintsadze, known as

protégé  of  Ukrainians  oligarchs
and

Vacancy DK-01910-2016/UKR.03-W  –  Senior Anti-Corruption Expert
was illegally transferred to former member of the Lithuanian delegation
for GRECO
who is directly responsible for ignoring
money laundering  going through Danske Bank  in Estonia, Latvia  and
Lithuania.  As is generally known,  former Ukrainian President Viktor
Yanukovich   stole nearly $1.5bn from the country. According to The
verdict of the Kramatorsk City Court from 28 March 2017 , ICU brokered
the purchase of dollar-denominated bonds on behalf of eight Cypriot
companies.  Everything was done via Latvian PrivatBank, Latvian Baltic
International Bank, Estonian Versobank, and the local branch of Danske
Bank.
2.  As estimated Chatham House, the Royal Institute of International Affairs(
“Are Ukraine’s Anti-corruption Reforms Working?” Research Paper

and
,  Russia and Eurasia Programme |
November 2018) EU Anti-Corruption Initiative in Ukraine 2017-2019
targeted not just underlying causes of corruption  but only symptoms. “The
present reality is that at some levels in international agencies and donor
governments, including in their embassies in Kyiv, there is sometimes only
fragmentary understanding of the problem.”
3.  Neither The Minister of Foreign Affairs of Denmark Mr. Kristian Jensen
nor
Support Group for Ukraine of the European
Commission Mr.
informed the European Anti-Fraud Office
(OLAF) about the facts of corruption within European Commission on the
case of acquisition IISW by Metinvest, SKM and Energees, reported by
me, and that is violation of Article 22a of Staff Regulations  No 31 (EEC),
11 (EAEC).
4.  European Anti-Fraud Office  OLAF dismissed the case 2OLAF-
OC20170347 because of a conflict of interest, since Director-General of
the European Anti-Fraud Office (OLAF) Mr Giovanni Kessler personally
participated in the organization Anti-Corruption Initiative in Ukraine
2017-2019 (ENI/2016/039-504)
5.  Ministry of Foreign Affairs of Denmark groundlessly attracted private
company Mercuri Urval A/S - Denmark for participation in the process of

appointment Anti-Corruption Staff, because created pre-conditions for
leaking database about anti-corruption experts and their families.
Personally for me such leaking can be fatal, because my knowledge touch
interests of influential persons.
6.   European Commission violated the  statement of paragraph 5(a) of Article
3 Council Regulation (EC) No 139/2004 of 20 January 2004 on the control
of concentrations between undertakings (the EC Merger Regulation)
because sending notification of a proposed concentration to European
Commission  Metinvest BV hasn’t received the consent of bondholders to
violate covenants.  Commission also ignored facts that before purchase
IISW’s shares Metinvest BV actively applied anti-competitive action on
purpose to deprive IISW on supplying with cheap raw materials. In
October 2006 I conducted journalistic investigation on these facts and
published  materials  in  the  weekly  “The  Island  (Остров)”  (№35,
04/10/2006, p.9). Now Metinvest BV listed $2.2 billion in worldwide
unpaid debt, including $ 1.1 billion in three series of Eurobond notes and
$ 1.1 billion in pre-export financing facilities. Only in 2012 Metinvest BV
had paid $400 million in dividends for owner

7.  Through European Capital market Metinvest BV has got illegally, for
indefinite term, considerable financial resources that has  used for support
Pro-Russian terrorists on Donbas. This support comes through the
mechanism of humanitarian help, while international humanitarian
organization are shut out from Donbas.
8.  Metinvest BV  is the owner of United Coal Company (UCC) in U.S. since
2009. It owns 18 mines and is the sixth largest metallurgical coal
recovering company in U.S. Metinvest BV avoided default of his
Eurobonds through corruption and now supplied coal to Ukraine from U.S.
mines for $71 per short ton. According to this scheme,  money is taken out
of the Ukraine  and transferred to the accounts of Metinvest’s  own
company in U.S., as profit.
Now I have reason to believe that my participation in the competition for vacancy
DK-01910-2016/UKR.03-W – Senior Anti-Corruption Expert, EU Anti-Corruption Initiative
in Ukraine for the Danish Ministry of Foreign Affairs / Danida became the reason for

repression of my family in Poland. In addition, I received signs that my location in Europe is
wanted by the private security service, related to Ukrainian oligarch

In the current difficult circumstances I seek protection as potential  whistleblower, in
accordance with Directive of the European Parliament and of the Council on the protection of
persons who report breaches of Union law .
Sincerely

Attachment:
1.  Copy of  the letter from Chair Committee on Petition of the European Parliament Ms Cecilia
Wikström.
2.   Job Profile Senior Anti-Corruption Expert (N2) EU Anti-Corruption Initiative in Ukraine
2017-2019.
3.  Copy of  the letter  for
Support Group  for Ukraine of the European
Commission Mr.

4.  Copy of  the letter from
Support Group for Ukraine of the European
Commission Mr.

5.  Copy of the letter from European Anti-Fraud Office OLAF.

Job Profile

Senior Anti-Corruption Expert (N2)

EU Anti-Corruption Initiative in Ukraine 2017-2019

Ukraine

Reference number: DK-01910-2016/UKR.03-W

1.
Preliminary

1.1.  Short background:
The  Danish  Ministry  of  Foreign  Affairs  is  looking  for  a  Senior  Anti-Corruption  Expert  for  its
Programme Implementing Unit (PIU) established to manage the EU Anti-Corruption Initiative
implemented by the Ministry of Foreign Affairs of Denmark (MFA).

1.2.  Purpose of memo:
This memo describes the main tasks involved in the position and the qualifications requested
from candidates to the job.

1.3.  Expected composition of the selection committee:
Applicants  for  the  position  will  be  selected  for  interview  by  The  Ministry  of  Foreign  Affairs
following  consultation  with  the  local  authorities,  who  might  also  be  represented  at  the  job
interview.  Mercuri  Urval  will  participate  in  the  process  of  appointment  by  conducting
personality tests and test interviews with the selected candidates, as well as taking part in the
final  interview.  The  final  interview  panel  consists  of  representatives  from  the  Ministry  of
Foreign  Affairs,  representatives  from  the  local  authorities,  and  the  consultant  from  Mercuri
Urval A/S in charge of the recruitment process.

2.
The Programme

2.1.  Corruption remains endemic in Ukraine and is an impediment to democratic development in
the country, which is one of the major objectives of the EU and Danish Neighbourhood policy.
Thus, anti-corruption in Ukraine is a high political priority for the EU and Denmark, and is a
foundation for other ongoing Danish and EU support to the country.

To support anti-corruption efforts, EU and Denmark have allocated EUR 15 and 1.34 million,
respectively,  for  this  cause.  Following  broad  consultation  with  all  interested  EU  Member
States and taking into account the substantial experience Denmark has with governance and
civil society programmes in Ukraine and the use of PIU arrangements, the EU has decided to
award the implementation of the EUR 15 million EU Anti-Corruption Initiative in Ukraine 2017-
2019 to Denmark, using the indirect implementation modality. The MFA is now looking for a
Senior Anti-Corruption Expert for the Programme Implementing Unit (PIU referred to as ‘One-
Stop-Shop’ in the Action Document – link below).

The  overall  objective  of  the  EU  Anti-Corruption  Initiative  in  Ukraine  is  to  improve  the
implementation  of  the  Ukrainian  anti-corruption  policy  by  supporting  the  relevant  anti-
corruption state institutions; strengthening oversight of reform implementation by Parliament;
1

and  at  regional  and  local  level  supporting  civil  society,  media  and  local  governments,  thus
substantially improving Ukraine's overall performance in the fight against corruption.

The programme will have three components:

1)  Support  capacity  building  of  anti-corruption  institutions,  including,  but  not  limited  to,
National  Agency  for  the  Prevention  of  Corruption  (NAPC),  the  National  Anti-Corruption
Bureau (NABU), the Specialised Anti-Corruption Prosecution Office (SACPO) and the State
Financial Monitoring Service (SFMS)
2)  Enhancing  parliamentary  oversight  via  support  to  the  Anti-Corruption  Committee  of  the
Parliament of Ukraine
3)  Support to civil society, local governments and media.

For more information on the proposed programme, see:

https://www.google.dk/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0ahUKEwjerfvS
cfOAhWEEiwKHWl4CdUQFggcMAA&url=http%3A%2F%2Fec.europa.eu%2Ftransparency%
2Fregcomitology%2Findex.cfm%3Fdo%3DSearch.getPDF%26YYbeywTKrsCgTfBvtrpeCVqB
B7fI4EnisQ1BdEUO8vCyEZEdggz%2Bn4JOVUqYppXe7kGvLzo2Pu5uyjPyPE0HGhn1Yyu8
a5hceFqN5ixnqYI%3D&usg=AFQjCNGrENAk9qW6vo5w0yJnsMzVE4alKg&sig2=hAo88WM
YhcMR5ahvkE05fg

The setup of the programme implementing unit
The  programme  will  be  implemented  by  Denmark  through  a  programme  implementing  unit
(PIU)  based  in  Kiev.  The  PIU  will  legally  be  a  project  implementation  unit  working  as  an
extended arm of the European Neighbourhood  department (EUN)  of the Ministry of  Foreign
Affairs  of  Denmark  (MFA)  and  will  operate  in  accordance  with  Danish  laws  and  regulations
as can be found on www.amg.um.dk.

The  PIU  will  have  full  oversight  of  the  programme  budget  on  a  day-to-day  basis.  The  PIU
team will report on progress on a monthly basis to the assigned programme officer in EUN of
the  MFA.  Furthermore,  the  PIU  will  function  as  a  secretariat  for  the  programme  steering
committee.

The PIU will also play a key role in streamlining donor efforts in the anti-corruption sector in
Ukraine. It will thus also serve as a secretariat for donor coordination and with the support of
EU  and  Denmark  push  for  a  joint  and  coordinated  strategy,  which  will  allow  for  concerted
anti-corruption efforts. Specific resources in the PIU will be assigned to this task.

The management tasks of the PIU will include:

  Planning and programming related to the programme
  Consolidated  reporting  across  components  and  partners,  including  analyses  and
recommendations,  to  allow  the  EU  and  the  Ministry  of  Foreign  Affairs  of  Denmark
(MFA) to undertake monitoring and policy decisions on an informed basis
  Management of funding to partners on behalf of the MFA
  Development and implementation of the EU Anti-Corruption Initiative’s communication
strategy
  Overall programme reporting and monitoring.

The PIU team will most likely consist of three international and six national staff members.

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The PIU services to partners
The PIU will provide support as requested by the beneficiaries in all three components of the
programme as well as a range of cross-cutting services. In practice the needs of partners will
be identified through:
  Strategy development processes
  Capacity development planning
  IT provision planning
  Ad-hoc needs identified by the institutions across all components as they emerge.

Specific services include:

Cross-cutting services
  Advising  on  anti-corruption  reform  processes  to  Ukrainian  Government  and
institutions, Parliament and donors
  Arranging events (such as conferences and hands-on workshops) related to  the fight
against corruption
  Assisting all relevant stakeholders with the development of cross-sector strategy and
planning processes
  Specific advice to the Government of Denmark and EU institutions as a background
for policy dialogue
  Advising  on  strategic  anti-corruption  related  communication  for  EU  institutions  and
Denmark.

Component 1 services
  Provision of regular advice and mentoring for component 1 institutions
  Provision of short term expertise
  Provision of capacity development packages
  Provision of IT solutions and equipment
  Other capacity development services to institutions as required
  Advice on strategic communication for component 1 institutions.

Component 2 services

Provision of regular advice and mentoring for the Ukrainian Parliament (Rada)

Provision of short term expertise

Provision of capacity development packages for the anti-corruption committee

Provision of funding to allow for an international advisory process on legislation

Provision of secretarial support to the international advisory process

Advise on strategic communication for the Rada anti-corruption work.

Component 3 services
  Provision of short term expertise to local governments in integrity cities
  Provision of grants for CSO capacity development for local anti-corruption initiatives
  Provision of grants for media for local anti-corruption initiatives
  Provision of related short term advice as required
  Advise on strategic communication for local government and civil society.

To  perform  these  services,  the  team  will  draw  on  a  number  of  modalities  to  assist  in  the
process (details still to be developed). These are likely to include:
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  Short-term expert roster of EU Member State (MS) anti-corruption institutions as well
as individual consultants
  A framework contract arrangement with EU member state institutions where they can
bid for more comprehensive capacity development assignments
  IT equipment procurement processes
  Providing grants for component 3 activities.

3.
The Position

3.1.  Title: Senior Anti-Corruption Expert (N2)

3.2.  Place of service: Programme Implementing Unit, Kiev.

3.3.  Terms of Employment according to Danida staff rules. Below non-exhaustive brief benefits:
Contract period: 3 years. Attractive remuneration package reflecting family status.
Contribution to a pension scheme, health insurance and reimbursement of school fees. Free
housing.

3.4.  Area of responsibility/tasks:
The Senior Anti-Corruption Expert will have thematic leadership of the support to institutions
under component 1 and 2 (NABU, NACP, SACPO, SFMS etc., and the Rada) as well as civil
society  and  media  organisations  and  local  administrations  under  component  3.  The  person
will lead the process of ensuring strategic planning processes across the institutions and the
development of capacity development plans, which will allow for donor coordination and the
procurement of capacity development packages for the institutions supported.

The strategic planning processes will be facilitated with the institutions leading the processes.
The  international  expert  and  the  team  of  national  experts  will  thus  serve  as  a  guide  to  the
institutions in this process.

Once  established,  the  expert  and  the  national  team  will  provide  substance  inputs  to  the
procurement processes and assist with recommendations in order to ensure that appropriate
tender documents are developed.

During the implementation the expert  will lead the thematic monitoring process and provide
inputs to the monthly and quarterly reports to the Head of the PIU.

Finally, the expert will provide inputs for policy recommendations for the MFA as well as the
EU as required.

The  expert  may  be  fielded  prior  to  programme  start  to  assist  with  the  establishment  of  the
PIU and prepare for the implementation.

3.5.  Success criteria:
The key success criterion is that the EU Anti-Corruption Initiative is implemented effectively
in accordance with objectives of the Initiative, agreed plans, timelines, budget and that
guidelines and accountability standards are respected according to guidelines of the MFA
and as per the contract with EU.

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A success criterion is to establish trustful relationships with all institutions and partners
involved under the EU Anti-Corruption Initiative in Ukraine. Furthermore, it is important to
establish ownership of the programme by the partners.

It is recognised by all involved that this is a very ambitious initiative that is to be implemented
in a highly complex environment.

4.
Demand Profile/Qualifications

4.1  Requirements and expectations concerning the candidates’ formal qualifications:
The  MFA  is  looking  for  an  experienced  Senior  Anti-Corruption  Expert  with  extensive
experience  from  anti-corruption  capacity  development  processes  from  other  transition
economies and with previous programme management experience. The person should have
strong interpersonal skills and the ability to work in a multicultural environment.

Key qualifications:
  Master’s degree in relevant field
  More than 10 years experience with capacity development and/or anti-corruption
  Experience working with public administration and political affairs and/or
judiciary/prosecution
  At least 5 years experience working in corruption prevention or investigating/
prosecuting corruption-related crimes in a national agency/institution
  Experience working with European and international institutions or non-governmental
organisations in the area of anti-corruption
  Fluent in English
  Experience in working in Eastern Europe or countries in transition would be an
advantage.
  Knowledge of Ukrainian and/or Russian an advantage.

4.2   Requirements and expectations concerning the personal qualifications of the candidates:
  Ability to seek quality results
  Ability to keep full confidentiality about all assigned tasks and related documentation
as  well  as  able  to  exercise  confidentiality,  discretion  and  tact  when  dealing  with
diverse groups of people
  High degree of communication and networking skills
  Ability to develop strong working relationships internally and externally at all levels.

5.
Recruitment Procedures

5.1  How do you apply:
Information about the mandatory application procedure can be found at:
www.danidajob.um.dk.  Reference  number  DK-01910-2016/UKR.03-W  should  be  stated  in
the application.

5.2  Deadline for applications: 29 September 2016 at 12 noon (CEST).

5.3  Preliminary  interviews  and  personal  evaluation:  31  October  –  2  November  2016.  Mercuri
Urval will conduct a personal evaluation of selected candidates.

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5.4  Language  test:  The  Ministry  of  Foreign  Affairs  has  decided  that  all  candidates  called  in  for
interview  -  except  for  those  to  whom  the  relevant  language  is  mother  tongue  -  shall  be
language tested in Denmark in the working language of the duty station (i.e. English).

5.5  Presentation to the appointments committee: 3-4 November 2016

5.6  Decision: A decision is expected during week 44.

5.7  Expected commencement: As soon as possible.
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