Legal, Ethical & Security Governance Framework

ORLOV&PARTNERS™ conducts its activities within the laws of Ukraine, the acquis of the European Union, and relevant international instruments, giving effect, where applicable, to directly applicable rules that regulate our field of activity. The Consultancy’s anti-corruption controls are informed by the OECD Convention on Combating Bribery of Foreign Public Officials and relevant national anti-corruption legislation. We act in accordance with the EU General Data Protection Regulation (GDPR), adapting compliance to each jurisdiction in which the Consultancy operates. Our compliance and quality management systems draw on ISO 37301 (Compliance Management), ISO 9001 (Quality Management) and ISO 37002 (Whistleblowing Management), the principles of which are embedded in our internal control policies. Where the Agency is engaged in politically sensitive or regulated projects, all decisions liable to have legal consequences are subject to mandatory prior clearance by the Legal Department.

Confidentiality is a core element of our professional practice. All information obtained in the course of an engagement is treated as confidential by default and protected under our internal protocols. Non-disclosure undertakings are implemented in line with Directive (EU) 2016/943 on the protection of trade secrets, the OECD Guidelines for Multinational Enterprises, the UNCITRAL Model Law on Electronic Commerce, and the applicable national laws of our operating jurisdictions. Electronic documents containing restricted or sensitive information are subject to enhanced internal legal oversight and safeguarded under our information-security procedures.

We act with respect for the individual, acknowledge inherent dignity and equal opportunities for all persons, and regard social responsibility as a key determinant of reputation. Our ethics policy is guided by ISO 26000 (Social Responsibility) and ESG principles. ORLOV&PARTNERS™ maintains a mandatory ex ante ethical impact assessment for any communication or commercial initiative prior to its public release. We enforce a strict prohibition on creating or disseminating materials likely to cause psychological or social harm.

ORLOV&PARTNERS™ recognises data protection as fundamental to its operations and processes personal and business data strictly in line with lawfulness, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality. Any request for disclosure of data is first reviewed by the Legal Department to assess the legal basis, necessity and proportionality of scope, and potential consequences. All data-processing activities are documented in accordance with the Concultancy’s internal procedures.

ORLOV&PARTNERS™ works only with information lawfully provided to it. Access to restricted information is governed by internal protocols defining access rights, permitted uses, and destruction procedures. Access is granted strictly on a need-to-know basis to individuals whose functional roles require it.

ORLOV&PARTNERS™ adheres to full political, religious, and corporate neutrality, ensuring independence of judgement and communication strategy. We maintain strict neutrality and eschew any actual or perceived bias. The Consultancy does not engage in activities that could compromise, or reasonably be perceived to compromise, our professional objectivity.

Any use of AI is aligned with the EU Artificial Intelligence Act (as applicable) and the EDPB Guidelines on AI and Personal Data (2023). Outputs generated through automated processing do not carry independent legal effect without human review. Final decisions are always taken by a human decision-maker. We maintain audit and assurance over algorithmic systems in line with the principles of explainability and human oversight as articulated by the European Commission. The Consultancy prohibits the use of AI for manipulation of public opinion, the creation of deceptive or fabricated narratives, or the simulation of human interaction in a manner likely to mislead.

Respect for human rights underpins all strategies. ORLOV&PARTNERS™ rejects disinformation, hate speech, defamation, discrimination, and any conduct that could reasonably be construed as political manipulation or deliberate distortion of facts.

This document is informational only and does not create legal obligations for the Consultancy or third parties. ORLOV&PARTNERS™ maintains a programme of continuous improvement of its internal policies, procedures and compliance systems, and may update this Framework from time to time without notice.