Survey results on the Memorandum on Competitive Ethics: high relevance of the principles and a call for joint action

23.06.2025

Energy Club, as the Coordinator of the Initiative on the Memorandum of Competitive Ethics in the Electricity Supply Market, thanks all signatory companies that participated in the survey. The collected feedback is extremely valuable for assessing the effectiveness of our joint initiative and determining further steps for its development.

The survey conducted among the parties to the Memorandum confirmed the high relevance of its principles for responding to current market challenges. At the same time, it highlighted key areas that require further joint work.

Key conclusions from the feedback received:

The principles of the Memorandum are relevant and realistic. Market participants highly assessed the compliance of the principles of the Memorandum with the current challenges in the electricity market (average score — 4.7 out of 5). The vast majority of respondents also confirmed that adhering to the ethical norms set out in the document in daily activities is a completely realistic task.

There is a need for the active work of the Ethics Committee. Although assessments of the current impact of the Memorandum on market transparency vary, it was clearly stated that problematic situations still exist in the market. In particular, this concerns “the behavior of some suppliers and traders in relations with consumers and among themselves, as well as the correctness of information in the information field”. This confirms the importance and necessity of the functioning of the Ethics Committee, provided for by the Memorandum, as an effective tool for considering such cases.

Specific directions for strengthening the Initiative have been identified. Survey participants made a number of constructive suggestions for improving the effectiveness of the Memorandum.

Among the key ideas:

• Increasing the transparency of pricing: Introducing clear and open price positions for all categories of consumers, including the budget sector.
• Creating an information exchange mechanism: Establishing data exchange between signatories regarding companies that do not adhere to the principles of integrity and fair competition.
• Involving the regulator: An important proposal was made to involve the National Commission for the Regulation of Energy and Utilities of Ukraine in the initiative to implement the provisions of the Memorandum in practice throughout the energy market of Ukraine.

Next steps

The main wish from market participants is to expand the circle of signatories to the Memorandum, because the more companies adhere to common ethical standards, the healthier and more transparent the market will become.

Energy Club, as the Initiative Coordinator, will use the responses received to plan further work, in particular to intensify the activities of the Ethics Committee and implement the proposed initiatives.

We are grateful for the cooperation and commitment to the principles of honest business and continue our joint work on the development of ethical standards in the energy market of Ukraine.