If a Legal Entity Has an Implemented Anti-Corruption Compliance Program, the Company Will Not Be Held Liable: Mariam Zadoyan”

Within the framework of the “Let’s Unite Forces to Prevent Corruption” campaign, on December 5, during the panel discussion titled “Business Integrity Policy in the Private Sector,” Mariam Zadoyan, representative of the CSOs Anti-Corruption Coalition of Armenia and anti-corruption expert at the Armenian Lawyers’ Association (ALA), also gave a speech.
The panel discussion was organized through the efforts of USAID, the Center for International Private Enterprise, and the Ministry of Justice.
Mariam Zadoyan announced that ALA is currently implementing the “BlowtheWhistle, Armenia” program with financial support from the United States Agency for International Development. The expert emphasized the importance of implementing anti-corruption compliance programs particularly in the private sector.
“The implementation of private sector whistleblowing systems is also encouraged for organizations operating in sectors with corruption risks, as well as organizations that frequently participate in public procurement tenders. The latter can be implemented as a component of anti-corruption compliance programs.
As we know, the institution of criminal liability for legal entities has been implemented in Armenia, which also states that if a company can prove it has taken steps to prevent corrupt acts by employees, but it still occurred, the company may be exempt from liability. Since the institution of criminal liability for legal entities is new in Armenia, there is not yet unified judicial practice on how the court will evaluate the implementation of anti-corruption compliance programs from the perspective of considering it as a circumstance excluding liability. Therefore, it is proposed to consider the application of anti-corruption compliance programs under the Criminal Code as a circumstance excluding or mitigating criminal liability for legal entities.”
For more details, see the video.