Principles of Work
Compliance and Principles of Work
Engaging with government authorities requires clear rules. Below are the principles that guide our work and the commitments we make when working with clients.
Commitments
How We Work
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01
Legality and Official Procedures
Our work is conducted exclusively within the law of the Kyrgyz Republic and established procedures.
We help build a well-founded position, determine the correct course of action, prepare the necessary materials, and organize professional engagement with state and municipal authorities.
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02
Anti-Corruption Position
We do not offer, promise, or make payments, gifts, or provide any other benefits to officials, their representatives, or persons connected to them in order to influence decisions.
This rule applies both directly and through third parties, and extends to unofficial payments intended to speed up or simplify administrative procedures.
We do not engage intermediaries or subcontractors for actions that conflict with these principles, and we expect partners involved in a project to observe the same requirements.
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03
No Guarantees of Government Decisions
We do not guarantee that a particular decision will be made by a state or municipal authority, and we do not claim to have influence over specific officials.
Our responsibility lies in the quality of preparation, the correctness of the chosen course of action, and the professional organization of the process. The decision itself is made by the relevant authority within the powers granted to it by law.
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04
Transparent Fees
The terms, scope of services, and fee amount are set out in advance by contract.
When supporting procedures that involve decisions by state or municipal authorities, our fee is never made contingent on obtaining a specific permit, approval, licence, or other government decision.
Our preferred engagement model is a fixed fee or retainer for an agreed scope of professional services.
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05
Conflicts of Interest
Before starting any engagement, we assess the project for potential or actual conflicts of interest.
If a material conflict is identified, we disclose it to the client and determine whether further work is possible, taking into account the nature of the conflict, contractual obligations, and confidentiality requirements.
Prior work in government bodies, and any restrictions potentially arising from it, is taken into account whenever it is relevant to a specific project.
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06
Confidentiality
Information about the client, the project, and the substance of the work is not disclosed to third parties without the client's consent, except as required by law or agreed under the terms of the contract.
Confidentiality obligations are set out in the contract or a separate agreement and may continue after the engagement ends.
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07
Client and Project Due Diligence
Before starting any engagement, we may request information about the client, its ownership structure, beneficial owners, participants, and the nature of the project, as needed to assess compliance risks.
Where necessary, we may carry out additional checks on the parties to the project, sources of financing, and other circumstances relevant to the decision to take on the engagement.
We reserve the right to decline a project if the available information is insufficient for a reasonable assessment of its legality or associated compliance risks.
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08
Right to Terminate the Engagement
If circumstances arise during a project that conflict with the law, the terms of the contract, or the principles set out here, we reserve the right to decline to carry out the relevant actions or to terminate the engagement in accordance with the contract and applicable law.
For Investors
For International Investors
We understand that engaging an adviser for government relations work can be viewed by international companies, investors, banks, and their legal counsel as a distinct area of compliance risk.
This may involve the client's internal compliance policies as well as applicable anti-corruption standards, including the FCPA (US), the UK Bribery Act, and the requirements of international financial institutions.
Within the scope of a specific project, we are ready to:
- complete compliance questionnaires and undergo counterparty KYC and due diligence procedures
- provide reasonably necessary corporate and professional information for verification
- include applicable anti-corruption clauses, warranties and representations in the contract
- sign non-disclosure agreements (NDAs)
- provide agreed reporting on the nature of work performed and project costs
- agree to reasonable client rights to a compliance audit of the services provided under a specific project
Applicable requirements are determined based on the client's jurisdiction, the nature of the project, and the terms of the specific contract.
Limitations
What We Don't Do
- We do not use unofficial payments as a means of resolving matters.
- We do not transfer or arrange the transfer of money, gifts, or other items of value to officials in order to influence their decisions.
- We do not guarantee permits, licences, approvals, tender outcomes, or other decisions of government authorities.
- We do not claim to be able to secure a government decision through personal influence over specific officials.
- We do not take actions intended to circumvent procedures established by law.
For us, government relations is not about obtaining a decision at any cost — it is about building a lawful, transparent, and documented process of engagement between business and government.
Contact
Have questions about how we work?
If your compliance process requires additional documents, checks, or contractual terms before starting an engagement, contact us to agree on the necessary format.