The Corporate Governance Professional Association (CGPA) and the Centre for CSR Development Ukraine (CSR Ukraine), supported by the Center for International Private Enterprise (CIPE), present the Company Transparency Index 2019, an assessment of Ukraine’s 100 largest taxpaying companies in 2019, as per the State Tax Service Data. The assessment analyzes the companies’ level of transparency in corporate governance and corporate social responsibility (hereinafter referred to as CSR) in 2019, before the pandemic caused by COVID-19.


The Center for International Private Enterprise (CIPE) is proud to support this initiative which aims to encourage companies to increase transparency and engagement with the broader Ukrainian business ecosystem. The companies on this list represent some excellent best practices in Ukraine and can serve as leaders in the country - creating a more inclusive, transparent business operating environment that offers more opportunities for more Ukrainians. The bright future of Ukraine relies on more companies “doing the right thing” and the leading companies highlighted in this report represent a strong foundation for the Ukrainian business community to build on. 

Eric Hontz, CIPE Deputy Regional Director, Europe & Eurasia

I am really grateful to the partners of the Project – CSR Ukraine and CIPE. Our cooperation made this study possible. We are pleased to find out that there is a whole group of companies (banks) in Ukraine which not only follow popular trends but truly practice what they preach, they promote specific values. These are the companies of the future. They can be attractive to investors, partners and employees. It is also essential for companies to promote themselves systematically and professionally, to establish a culture of openness and develop their unique style of “communication” with the business environment in the broadest sense of the word. For the first time, we decided to pay attention to the personal leadership style of senior executives, because we believe that if the company supports environmental projects, for example, the CEO should share these ideas and be personally involved in such types of projects not only as a manager but also as a citizen. It was our first experience of conducting this particular type of such a comprehensive study; we are planning to continue in the future improving our methodology. Constructive criticism and any suggestions are welcome! We are open to cooperation. 

Oleksandr Okuniev, Chairman of the Management Board of the Corporate Governance Professional Association

The CSR Development Center has been implementing the Transparency Index for eighth year in a row. But this year is special – this Transparency Index is conducted in partnership with two well-known organizations – the Corporate Governance Professional Association of and CIPE. I am grateful to the partners for this opportunity, support, and expertise. The site is a tool for communication with stakeholders. That is why we evaluate not only general information about the company but also the results of the company’s work in many areas – human rights, gender equality, corporate governance. That is important for investors, potential employees, NGOs, and the media. The Transparency Index 2019 has updated components – corporate governance, gender equality, and leadership. The Index results show interesting results: the overall level of transparency remains low, although state-owned companies perform better in the Transparency Index than private ones. I hope the Transparency Index 2019 will help companies improve their sites and be inspired by the TOP-10 Index leaders’ example. 

Maryna Saprykina, Head of the Board for CSR Ukraine


The companies analyzed in this report disclose information regarding their corporate governance policies, employee relationships, environmental protection initiatives, and community relations the most frequently on their respective websites. Human rights policies, level of CSR integration in supply chains, and corporate leadership information are disclosed on companies’ websites the least. The ten companies with the highest levels of transparency in the Company Transparency Index 2019 disclose twice as much information in the Index Content and Reporting categories than the other companies analyzed.



The largest Ukrainian companies typically place their company’s general information, profile, and, quite often, the company’s history and awards on their corporate websites. The practice of placing mission, goals, and strategy is not yet commonplace in the Ukrainian business environment.


The website of LLC “Lemtrans”, a company apart of the SCM Group, contains the SCM Group’s Sustainable Development Policy. Some companies provide information about their sustainable development strategies in their non-financial reports (e.g. JSB “Ukrgasbank”). Other companies’ non-financial reports only contain general information about the significance of other companies’ CSR policies. The integration of the UN’s Sustainable Development Goals in Ukrainian companies’ CSR policies is extremely low. Seven Ukrainian companies mentioned the UN’s Sustainable Development Goals on their corporate website pages, and only two of them disclosed their clear commitments to achieving the goals.


75 companies in the Transparency Index 2019 placed information regarding corporate governance policies on their websites

The companies usually disclose information about their governing bodies, management, and the elimination of corruption for shareholders and investors.

Some companies mention the existence of an anti-corruption program, a commissioner for anti-corruption programs, and available communication channels in their Management Reports. The information disclosure level concerning the implementation of companies’ anti-corruption programs is also low. In 2019, only JSC “Ukrainian Railways,” NNEGC “Energoatom,” PrJSC “Ukrhydroenergo,” SE “Ukraine Sea Port Authority,” JSC CB “Privatbank,” and SC “Ukrposhta” posted the results of anti-corruption implementation on their websites. Only PJSC “Credit-Agricole Bank” provided data regarding certification of the ISO 37001 standard, “Anti-bribery management systems – Requirements with guidance for use,” on the website. In our opinion, disclosures on the prevention of corruption are higher among state-owned enterprises and banks compared to other companies due to the approval of relevant regulatory documents. The publication of information regarding rewards to management staff is a relatively new concept to the Ukrainian business environment. Only JSC “NJSC “Naftogaz of Ukraine” placed this information on its website.

The practice of disclosing information concerning ownership structure, the establishment of corporate social responsibility governance structures, and stakeholder engagement is not common in the Ukrainian companies’ corporate governance system. Only 5 companies, JSB “Ukrgasbank,” JSC Ukrtransnafta, PJSC “ArcelorMittal Kryvyi Rih,” JSC “Ukrainian Railways,” and NNEGC “Energoatom” published their stakeholder engagement plans. JSC “First Ukrainian International Bank,” JSC “Ukrainian Railways,” NPC “Ukrenergo,” and JSC “Farmak” mentioned departments or persons responsible for their CSR policies on their corporate website pages.


Ukrainian companies do not regard corporate websites as an effective tool of transparency or an efficient stakeholder of communication channels. The fact that the companies analyzed in this report provide more information about their CSR policies or CSR practices rather than the implementation of CSR policies and practices supports this conclusion. Implementation results of CSR policies and practices are most often provided by the companies in their non-financial and management reports.

Companies disclose information regarding their policies and programs concerning environmental protection, employee relationships, community relations, and some corporate governance aspects (company management, membership of supervisory boards, information for investors, anti-corruption programs) the most frequently. There is no information (perhaps, no implementation practice as well) regarding the protection of human rights, CSR integration in the supply chain, and management and company leadership. Only 6 companies published their 2019 nonfinancial reports on their websites. Companies most likely postponed the deadlines of non-financial reporting due to the COVID-19 pandemic and the lack of normative and legal regulation influenced the collection and analysis of management reports.

State-owned enterprises have higher indicators of transparency than private companies in every Transparency Index component

More than a half of the companies among the Transparency Index Top 10 are state-owned. In our opinion, this is a positive sign of corporate governance reform in Ukrainian state-owned enterprises. The highest disclosure level is demonstrated by companies in financial sector, transportation, and electricity, many of them are state-owned.

Full results can be downloaded here