Expert Opinion
Subject: Conflict of Interest at the UN Working Group on Arbitrary Detention in Opinion No.
46/2024 regarding Ruben Vardanyan v. Azerbaijan
By Luis Moreno Ocampo
October 2025.
Executive Summary
On February 17, 2025, the UN Working Group on Arbitrary Detention (WGAD) released Opinion
No. 46/2024 Ruben Vardanyan (v. Azerbaijan). The opinion concluded that Ruben Vardanyan's
detention by Azerbaijan was not arbitrary.
1
A different perspective was presented by UN High Commissioner for Human Rights, M. Volker
Türk, during his address to the Human Rights Council on March 3, 2025. Mr. Türk demanded
that “all those arbitrarily detained in Azerbaijan, including ethnic Armenians, must be released
immediately, and fair trial rights must be respected fully.”
2
Luis Moreno Ocampo, the first Prosecutor of the International Criminal Court conducted an open-
source investigation about the impartiality of Ms. Ganna Yudkivska, current Chair-Rapporteour of
the WGAD, in relation to Opinion No. 46/2024 concerning Ruben Vardanyan (Azerbaijan) and
other cases against Azerbaijan.
It is reasonable to believe that Ms. Ganna Yudkivska, a Ukrainian lawyer appointed to the WGAD
in October 2022, should have abstained from all cases brought to the UN Working Group against
Azerbaijan. In short, she has a conflict of interest arising from her professional work as an active
partner at Equity Law Firm, which has for years provided legal services and representation for the
State Oil Company of the Azerbaijan Republic (SOCAR). This establishes a direct financial link
between her and the Azerbaijani Government, a party to Opinion 46/2024 proceedings.
This situation contravenes Articles 3(a), 3(d), 3(e), and 3(i) of the Code of Conduct, which
mandates independence, impartiality, integrity, and the prohibition of private gain, as well as
Regulation 2(h) of ST/SGB/2002/9, which requires recusal when financial interests overlap with
United Nations functions. Her failure to disclose this role or to abstain from related proceedings
1 Opinion No. 46/2024 concerning Ruben Vardanyan (Azerbaijan), A/HRC/WGAD/2024/46, 17 February 2025.
2 United Nations Human Rights Office of the High Commissioner, “Turbulence and unpredictability amid growing
conflict and in divided societies, Türk tells Human Rights Council”, 3 March 2025. The website has been archived:
Archive 1, Archive 2. [consulted on 14 September 2025].
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further constitutes a breach of Paragraph 5 of the WGAD Methods of Work, which stipulates
recusal in cases where conflicts of interest exist.
In addition, Ganna Yudkivska did recuse herself in cases involving Russia but joined a WGAD
opinion for Ruben Vardanyan, an individual sanctioned by Ukraine for his purported
connections with Russia. Furthermore, she co-founded the War Damage Institute LLC, a
Ukrainian legal firm linked to Equity Law Firm, focusing on damages caused by Russia's invasion.
This selective application of abstention obligations undermines impartiality, contrary to Article
3(a) and Article 5 of the Code of Conduct (duty of impartiality and solemn declaration of
independence).
Finally, Ganna Yudkivska’s husband, an Ukrainian politician who is subject to an arrest warrant
for corruption related to a case at the European Court of Human Rights (ECHR) (when Yudkivska
was a judge there), is reported to have strong personal and political ties to Azerbaijan. He stated in
the media that “without a doubt, Nagorno-Karabakh is an integral part of Azerbaijan.”
3
It is worth
noting that the case of Ruben Vardanyan is directly connected to the Azerbaijan attack against
Nagorno-Karabakh population, and naturally, it involves a case against Azerbaijan.
According to Article 3(i) of the Code of Conduct, mandate-holders must refrain from permitting
family connections to generate conflicts of interest, and under Article 12(b), they must avoid
behavior that undermines the recognition of their independence.
As a consequence, there are reasonable grounds to believe that mandate holder Ganna Yudkivska
participation in cases related to Azerbaijan, including her Opinion No. 46/2024 breaches the
Methods of work of the Working Group on Arbitrary Detentions (A/HRC/36/38) Paragraph 5 and
articles 2, 3, 5, 12, and 15 of the Code of Conduct for Special Procedures Mandate-holders of the
Human Rights Council (A/HRC/RES/5/2) and the Regulations Governing the Status, Basic Rights,
and Duties of Officials (ST/SGB/2002/9), which clearly state that mandate-holders must act
independently, impartially, and free from external influence, and requires them to recuse
themselves when a conflict of interest may arise.
I.- INTRODUCTION
During the 51st session of the Human Rights Council (September 12 – October 7, 2022), the
Council President appointed Dr. Ganna Yudkivska as the Eastern European member of the
WGAD.
Mandate holders of the WGAD operate under a strict Code of Conduct established in Human
Rights Council Resolution 5/2 (Annex, 2007). This Code requires that all mandate holders act with
independence, impartiality, integrity, and objectivity. Article 3(f) obliges them to disclose any
3 AzVision.az, “Vice-président de l`APCE: «l`Azerbaïdjan est toujours dans mon coeur» – EXCLUSIVE”, 26 January
2017. The website has been archived: Archive 1, Archive 2. [consulted and archived on 16 September 2025].
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actual or potential conflict of interest and to abstain from participating in deliberations where such
a conflict may arise, including when personal, professional, or financial interests could reasonably
call their impartiality into question.4
Impartiality is a fundamental characteristic of UN mandate holders. It is required by articles 4 and
12 of UN General Assembly Resolution 60/251 of 15 March 2006, entitled “Human Rights
Council” (A/RES/60/251), article 39 of Resolution 5/1 of 18 June 2007 of the Human Rights
Council, “Institution-building of the United Nations Human” (A/HRC/RES/5/1), the Manual of
Operations of the Special Procedures of the Human Rights Council, articles 2, 3, 5, 12, and 15 of
the Code of Conduct for Special Procedures Mandate-holders of the Human Rights Council
(A/HRC/RES/5/2), and Regulations 2 (h) and 3 of the Regulations Governing the Status, Basic
Rights and Duties of Officials other than Secretariat Officials, and Experts on Mission
(ST/SGB/2002/9), and Paragraph 5 of the Methods of Work of the Working Group on Arbitrary
Detention (A/HRC/36/38).
Additionally, the Methods of Work of the Working Group on Arbitrary Detention (A/HRC/36/38)
article 5 establishes: “When the case under consideration or the country visit concerns a country
of which one of the members of the Working Group is a national, or in other situations where there
may be a conflict of interest, that member shall not participate in the discussion of the case, in the
visit or in the preparation of the report on the visit.”5
WGAD member Ganna Yudkivska has conflicting interests that she should have disclosed before
withdrawing from any participation in the deliberations of Opinion 46/2024. This conflict of
interest is threefold:
● First, it has been established that Hanna Yudkivska is a lawyer and active partner, thus
financially compensated, of Equity Law Firm, a legal office based in Ukraine, which
provides legal services and representation for the State Oil Company of the Azerbaijan
Republic (SOCAR), the country’s leading state-owned enterprise. At a minimum, this
creates a direct connection between the WGAD member, Ganna Yudkivska, and the
Government of Azerbaijan. This is more than sufficient to create a conflict of interest
because she would not want her work outside her law firm to cause any problems for a top
client of her law firm. But it may be even worse. If she is compensated as a partner, in any
part, from a pooling of law firm profits across all its clients that are then distributed to the
partnership based on individual performance, as is typical at law firms, then this means that
part of her ongoing compensation as a lawyer is coming directly from the Government of
Azerbaijan, even if she isn’t involved in representing the Government as a lawyer.
4 Code of Conduct for Special Procedures Mandate-holders of the Human Rights Council A/HRC/RES/5/2, 18 June
2007.
5 Methods of work of the Working Group on Arbitrary Detention, A/HRC/36/38, 13 July 2017.
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● Moreover, in previous cases involving the Russian Federation, Ganna Yudkivska
abstained from participating. However, in the case involving, Ruben Vardanyan, whom
the Ukrainian government sanctioned for allegedly supporting Russia, Ganna Yudkivska
did not abstain from participating. Furthermore, Ganna Yudkivska is the co-founder and
owns 50% of the shares, alongside Oleh Malinevsky, who holds the other 50% of shares
(and is also one of the owners of Equity Law Firm), of the War Damage Institute LLC,
a Ukrainian legal office focused on actions to address damage caused by the Russian
invasion.
● Finally, her husband, Georgii Logvynskyi, has Azerbaijani origins and is reported to fully
support Azerbaijan in the discussion on Nagorno-Karabakh.
These findings raise concerns about impartiality and independence in deliberations related to
Azerbaijan, especially in cases connected with the conflict with Nagorno-Karabakh population.
II.- BACKGROUND OF OPINION No. 46/2024
On 17 February 2025, the WGAD published Opinion No. 46/2024 regarding Ruben Vardanyan
(Azerbaijan). The opinion was adopted at its 101st session, held from 11 to 15 November 2024. At
the time, WGAD member Ganna Yudkivska, then Vice-Chair on Communications, participated in
the session. The opinion concluded that Ruben Vardanyan’s detention was not arbitrary.
Opinion No. 46/2024 deals with a case concerning Azerbaijan's arrest and detention of Ruben
Vardanyan. He served as the Minister of State (Prime Minister) in the Government of Nagorno-
Karabakh between 4 November 2022 and 23 February 2023. He is a business leader, social
entrepreneur, philanthropist and human rights defender, including for the right to self-
determination of the Armenian population living in Nagorno-Karabakh.
It is unknown whether she was the case rapporteur, but given her background in the region and
other members aren’t from the region, it would not be surprising if she led the Working Group’s
engagement on the case and drafted the Opinion for review by other members.
On 19 of September 2023, Azerbaijan launched a military attack on Nagorno-Karabakh removing
a population of nearly 120.000 ethnics Armenians from the land they occupied for thousands of
years. On 27 September 2023, Ruben Vardanyan was detained by the Azerbaijan Border Service
as he attempted to cross the Lachin checkpoint into Armenia.
Many human rights bodies have expressed significant concern about the aggression of Azerbaijani
forces against Nagorno-Karabakh, and the detention of political leaders, including Mr. Vardanyan.
The UN Special Adviser on the Prevention of Genocide alerted about the risk of genocide the
Nagorno-Karabakh people. 6
6 UN Press Release, Statement by Ms. Alice Wairimu Nderitu, Special Adviser on the Prevention of Genocide, on the
situation in Armenia and Azerbaijan, 22 September 2023. Special Adviser Nderitu stated “on September 22, 2023,
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The UN High Commissioner for Human Rights stated on 3 March 2025 that “all those arbitrarily
detained in Azerbaijan, including ethnic Armenians, must be released immediately, and fair trial
rights must be respected fully”
7
(referring to the individuals detained during the 2023 aggression,
including Mr. Vardanyan).
The International Court of Justice (ICJ)’s provisional measures of 17 November 2023 ordered
Azerbaijan to ensure that all “persons who remained in Nagorno-Karabakh after 19 September
2023 or returned to Nagorno-Karabakh and who wish to stay are free from the use of force or
intimidation that may cause them to flee”8
.
The European Parliament has taken several consecutive resolutions on the matter, such as
Resolution 2023/2879(RSP) of 5 October 2023, which considered “a gross violation of human
rights and international law […] [which] amounts to ethnic cleansing […] the threats and acts of
violence committed by Azerbaijani troops against the population of Nagorno-Karabakh”9
.
Resolution No. 2024/2580(RSP) of 13 March 2024 stated that “a number of Armenians are still
being held in Azerbaijan, including the former leaders of Nagorno-Karabakh; some being
interviewed and submitted to public curiosity contrary to the 1929 Geneva Conventions”10
.
Resolution 2024/2890(RSP) of 24 October 202411 and Resolution 2024/2994(RSP) of 16
December 202412 both reference “23 Armenian prisoners of war” detained following Azerbaijan’s
retaking of the region, “including leaders of the former self-proclaimed Nagorno-Karabakh
republic” such as Ruben Vardanyan13
. Resolution 2025/2596(RSP) of 13 March 2025 “recalled
that Armenian hostages are being detained in Azerbaijan, including former de facto Nagorno-
Military action …put the civilian population in the area at risk of violence, including risk of genocide and related
atrocity crimes.” [consulted on 15 September 2025].
7 United Nations Human Rights Office of the High Commissioner, “Turbulence and unpredictability amid growing
conflict and in divided societies, Türk tells Human Rights Council”, 3 March 2025. The website has been archived:
Archive 1, Archive 2. [consulted on 14 September 2025].
8
International Court of Justice (ICJ), “Order of 17 November 2023”, 17 November 2023. The website has been
archived: Archive 1, Archive 2 [consulted on 15 September 2025].
9 European Parliament, “European Parliament resolution of 5 October 2023 on the situation in Nagorno-Karabakh
after Azerbaijan’s attack and the continuing threats against Armenia (2023/2879(RSP)”, October 5, 2023. The website
has been archived: Archive 1, Archive 2. [consulted on 13 September 2025].
10 European Parliament, “European Parliament resolution of 13 March 2024 on closer ties between the EU and
Armenia and the need for a peace agreement between Azerbaijan and Armenia (2024/2580(RSP))”, 13 March 2024.
The website has been archived: Archive 1, Archive 2. [consulted and archived on 15 September 2025].
11 European Parliament, “European Parliament resolution of 24 October 2024 on the situation in Azerbaijan, violation
of human rights and international law and relations with Armenia (2024/2890(RSP)”, European Parliament, 24
October 2024. The website has been archived: Archive 1, Archive 2. [consulted on 13 September 2025].
12 European Parliament, “European Parliament resolution of 19 December 2024 on the continued repression of civil
society and independent media in Azerbaijan and the cases of Dr Gubad Ibadoghlu, Anar Mammadli, Kamran
Mammadli, Rufat Safarov and Meydan TV”, 16 December 2024. The website has been archived: Archive 1, Archive
2. [consulted and archived on 14 September 2025].
13 European Parliament, “European Parliament resolution of 19 December 2024 on the continued repression of civil
society and independent media in Azerbaijan and the cases of Dr Gubad Ibadoghlu, Anar Mammadli, Kamran
Mammadli, Rufat Safarov and Meydan TV”, 16 December 2024. The website has been archived: Archive 1, Archive
2. [consulted and archived on 14 September 2025].
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Karabakh officials and prisoners of war […] undergoing sham trials and facing serious charges
that could result in illegal life imprisonment sentences”14
.
Similarly, the European Union Committee of the Regions (CoR) published a resolution on 11
October 2023 calling for “the immediate release of Armenian civilians and local officials from
Nagorno-Karabakh who were abducted and arrested by Azerbaijan”15
.
The High Representative of the European Union for Foreign Affairs and Security Policy also
made several statements on the issue, which were gathered to be submitted cohesively before the
UN Security Council on 21 March 2023 to denounce the arbitrary detention and other human
rights violations affecting the Armenians from Nagorno-Karabakh16
.
The Parliamentary Assembly of the Council of Europe (PACE), following the “Humanitarian
situation in Nagorno-Karabakh”17 report drafted by the Committee on Migration, Refugees, and
Displaced Persons, issued Resolution 2517 on 12 October 2023 expressing concerns about the
alleged “ethnic cleansing” taking place in the region18
.
Multiple other NGOs have also reported on the human rights violation surrounding the Nagorno-
Karabakh conflict, such as Amnesty International, expressing concerns about the alleged
unlawful arrest of Mr. Vardanyan and other government officials19
.
It is also important to note that the International Committee of the Red Cross (ICRC), the sole
international organization permitted to visit the Armenian detainees, was expelled from the
country. The announcement was made in March 2025, with implementation occurring in
September 2025. The final visit to Armenian civilians and government officials detained in
Azerbaijan took place in June 2025. 20
14 European Parliament, “Resolution on the unlawful detention and sham trials of Armenian hostages, including high-
ranking political representatives from Nagorno-Karabakh, by Azerbaijan”, 12 March 2025. The website has been
archived: Archive 1, Archive 2. [consulted on 14 September 2025].
15 European Committee of the Regions, “Resolution of the European Committee of the Regions on the Situation in
Nagorno-Karabakh after Azerbaijan’s attack”, 11 October 2023. The website has been archived: Archive 1, Archive
2. [consulted and archived on 14 September 2025].
16 High Representative, “Azerbaijan: Address by the High Representative Josep Borrell to UN Security Council on
Nagorno-Karabakh”, 22 March 2023. The website has been archived: Archive 1, Archive 2. [consulted and archived
on 15 September 2025].
17 Parliamentary Assembly of the Council of Europe (PACE), “Humanitarian situation in Nagorno-Karabakh”,
Committee on Migration, Refugees and Displaced Persons, PACE, 10 October 2023. The website has been archived:
Archive 1. [consulted on 13 September 2025].
18 Parliamentary Assembly of the Council of Europe (PACE), “The humanitarian situation in Nagorno-Karabakh”,
12 October 2023. The website has been archived: Archive 1 [consulted and archived on 18 September 2025].
19 Amnesty International, “Azerbaijan: Authorities must ensure fair trial rights of Ruben Vardanyan and investigate
claims of rights violations”, 17 January 2025. The website has been archived: Archive 1, Archive 2. [consulted and
archived on 15 September 2025].
20 ICRC, “The International Committee of the Red Cross closes its delegation in the Republic of Azerbaijan”, 2
September 2025. The website has been archived: Archive 1, Archive 2 [consulted and archived on 15 September
2025].
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Timeline of Opinion 46/2024
On 20 March 2024, Ruben Vardanyan's legal counsel filed a communication seeking an opinion
from the WGAD against the Republic of Azerbaijan.
On 15 May 2024, the WGAD transmitted the allegations from the source to the Government of
Azerbaijan through its regular communications procedure.
On 12 July 2024, the Government of Azerbaijan requested an extension, which was granted.
The WGAD received Azerbaijan's response on 15 August 2024.
The victim's representative responded to submission of the Government of the Republic of
Azerbaijan on 18 August 2024.
On 11 November 2024, the WGAD adopted Opinion No. 46/2024 concerning Ruben Vardanyan
vs. Azerbaijan, that became public on 17 February 2025.
Throughout this entire period during which Ruben Vardanyan's complaint against the Republic
of Azerbaijan was being processed by the WGAD, from 20 March 2024 to 17 February 2025,
Ganna Yudkivska was a WGAD member serving as Vice-Chair on Communication as well as a
partner at Equity Law Firm, the main client of which is SOCAR, the primary state-owned
company of Azerbaijan presided by the same national leader, Aliyev.
This direct connection with Azerbaijan was not revealed during Mrs. Yudkivska’s participation in
Ruben Vardanyan v. Government of Azerbaijan, although it undoubtedly compromises the
impartiality required for mandate-holders in their roles. Yudkivska’s position as a partner at a firm
representing Azerbaijani state interests raises legitimate concerns about her impartiality in the
Ruben Vardanyan case before the WGAD, as well as in any future cases involving Armenian
complaints against Azerbaijan or Azerbaijani political dissidents.
Azerbaijan’s government has consistently employed SOCAR, its state-owned energy company,
as a tool of undue political influence, including through the payment of bribes to foreign
officials. This practice was underscored in 2024, when U.S. Congressman Henry Cuellar (D-TX)
and his wife were indicted for accepting at least $360,000 in bribes from an oil and gas
company wholly owned and controlled by the Government of Azerbaijan (SOCAR), in
exchange for “influence U.S. foreign policy in favor of Azerbaijan.”21
21 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS, HOUSTON
DIVISION, Case 4:24-cr-00224, US v. Enrique Roberto “Henry” Cuellar and Imelda Rios Cuellar Filed on April
30th 2024. Consulted on 27 September 2025.
https://static.texastribune.org/media/files/1785edc5514548f418e6fb62e9659fb7/Cuellar%20Indictment.pdf
see also https://www.nytimes.com/2024/05/04/us/politics/azerbaijan-cuellar-lobbying-armenia.html
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Similar tactics were exposed in the “Caviar Diplomacy” scandal, where Azerbaijani officials used
lavish gifts and illicit payments to influence members of the Parliamentary Assembly of the
Council of Europe (PACE) to soften criticism of Azerbaijan’s human rights record. Together, these
examples illustrate a systematic strategy of using SOCAR and related channels to buy political
support and suppress accountability.22
III.- FACTS RELATED TO THE CONFLICT OF INTEREST
III.1.- Ganna Yudkivska is a lawyer and active partner at Equity Law Firm, a legal office that
provides legal services and representation for the State Oil Company of the Azerbaijan Republic
(SOCAR), thereby creating a direct connection between the mandate-holder and the
Government of Azerbaijan and potentially an economic connection as well.
Dr. Yudkivska has a financial interest in Azerbaijan’s state-owned company, the State Oil Company
of the Republic of Azerbaijan (SOCAR), since Dr Yudkivska is a partner of the law firm that
represents SOCAR activities in Ukraine.
23 In September 2023, the Ukrainian law firm Equity Law
announced the incorporation of Dr. Yudkiska as a partner to the firm,24 a position she has held to
this date.25
22 See et al. European Stability Initiative (ESI), “Caviar diplomacy. Why every European should care”. 2021. The
website has been archived: Archive 1, Archive 2 [consulted and archived on 18 September 2025]; Organized Crime
and Corruption Reporting Project (OCCRP), “US Lobbying Firm Launders Azerbaijan’s Reputation — And Gets
‘Laundromat’ Cash”, 23 May 2018. The website has been archived: Archive 1, Archive 2 [consulted and archived on
18 September 2025]; Organized Crime and Corruption Reporting Project (OCCRP), “Baku’s Man in America”, 23
May 2018. The website has been archived: Archive 1, Archive 2 [consulted on 18 September 2025]; Politico,
“Corruption allegations threaten to wreck Muscat’s premiership”, 26 April 2017. The website has been archived:
Archive 1, Archive 2 [consulted and archived on 14 September 2025]; Deutsche Welle, “Germany's CDU 'received
money from Azerbaijan”, 26 October 2017. The website has been archived: Archive 1, Archive 2 [consulted and
archived on 14 September 2025]; Washington Post, “House committee clears 9 lawmakers who went on Azerbaijan
trip in 2013”, 31 July 2015. The website has been archived: Archive 1, Archive 2 [consulted and archived on 18
September 2025]; The Economist, “Caviar Diplomacy in Azerbaijan”, 31 August 2016. The website has been
archived: Archive 1, Archive 2 [consulted on 14 September 2025]; Washington Post, “10 members of Congress took
trip secretly funded by foreign government”, 13 May 2015. The website has been archived: Archive 1, Archive 2
[consulted on 14 September 2025]; Roll Call, “Justice Department Issues Indictment for 2013 Congressional Trip to
Azerbaijan”, 24 September 2018. The website has been archived: Archive 1, Archive 2 [consulted and archived on 14
September 2025]; Department of Justice, “Former Non-Profit President Pleads Guilty to Scheme to Conceal Foreign
Funding of 2013 Congressional Trip”, 10 December 2018. The website has been archived: Archive 1, Archive 2
[consulted on 14 September 2025]; Italian Institute for International Political Studies (ISPI), “Azerbaijan’s New Faces
of Caviar Diplomacy”, 5 February 2024. The website has been archived: Archive 1, Archive 2 [consulted and archived
on 14 September 2025]; Politico, “Azerbaijan crisis raises fresh scrutiny over EU lobbying battle”, 28 September
2023. The website has been archived: Archive 1, Archive 2 [consulted and archived on 14 September 2025]; Organized
Crime and Corruption Reporting Project (OCCRP) “The Influence Machine”, 4 September 2017. This website has
been archived: Archive 1, Archive 2 [consulted and archived on 14 September 2025].
23 Equity Law official website. https://equity.law/en/projects/
24 https://equity.law/en/press-center/news/hanna-yudkivska-joins-EQUITY-as-partner.html
25 https://equity.law/en/team/partners/hanna-yudkivska.html
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SOCAR in Ukraine is owned by the State Oil Company of the Azerbaijan Republic (SOCAR). The
company, known as SOCAR Energy Ukraine, serves as the Ukrainian subsidiary of the Azerbaijani
state oil company.26
Dr. Yudkivska’s role as a partner at a firm that represents Azerbaijani state interests raises valid
concerns about her impartiality in the Ruben Vardanyan case before the UN WGAD, as well as in
any future cases involving Armenian complaints against Azerbaijan or Azerbaijani political
dissidents.
Equity Law (“Equity”) is a Ukrainian law firm registered as three separate legal entities at the
same address, sharing ownership and legal activities: two Limited Liability Companies (LLC) and
an Advocates’ Association (Адвокатське об’єднання).
Her new role was covered in local news: for example, the website “Ukrainian Law Firms" (a
handbook for foreign clients) announced that “Hanna Yudkivska joins EQUITY as a partner”, all
while explicitly mentioning her “current UN mandate”27
.
The Equity Law Firm website28 lists Hanna Yudkivska as a “partner” at the law firm, explicitly
noting her simultaneous role as “Chair-Rapporteur of the UN Working Group on Arbitrary
Detention”29
. Hanna Yudkivska is listed on the “Team” tab, not as a “Counsel” or a “Senior
26 European Business Association. https://eba.com.ua/en/member/tov-sokar-enerdzhi-ukrayina/
27 Ukranian Law Firms, A Handbook for Foreign Clients, Hanna Yudkivska joins EQUITY as a partner, 22 September
2023. The website has been archived: Archive 1, Archive 2 [consulted and archived on 9 September 2025].
28 Equity Law Firm, Home. The website has been archived: Archive 1, Archive 2 [consulted and archived on 9
September 2025].
29 Equity Law Firm, Ganna Yudkivska – Partner. The website has been archived: Archive 1, Archive 2 [consulted and
archived on 9 September 2025].
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Associate”, but as a “Partner”30. If the website is modified or the information is changed, archives
of the website have been created.
There are two further concerning things to note about Dr. Yudkivska’s employment as a partner
with Equity Law Firm, which raises concerns that she may have actively sought to hide this
affiliation, to the extent that is possible.
First, although she is a member of the WGAD as Ganna Yudkivska and was a member of the
European Court of Human Rights using the same name, across her law firm website and any media
connected to her employment at Equity Law Firm, her name is English is consistently spelled
Hanna Yudkivska.
And second, although she was appointed to be a partner in Equity Law Firm in September 2023,
her online biography at the UN makes no mention of this position,31 even though it is her primary
employment. This is a highly-material omission that irrespective of her intent has the actual effect
of making it impossible for the public-at-large to effectively identify potential conflicts of interest
that she might have coming from her current work.
When one considers together that when she applied to become a member of the Working Group
that she wasn’t yet employed by Equity Law Firm, so it wasn’t on her application, that despite
being a partner for two years it isn’t on her WGAD biography, and that in her work for the law
firm she uses a different spelling of her first name, this meant no one could easily find a connection
between her and the Government of Azerbaijan, And yet, it is indisputable.
30 Equity Law Firm, Team. The website has been archived: Archive 1, Archive 2 [consulted and archived on 9
September 2025].
31 UN Working Group on Arbitrary Detention, Current Members [consulted and archived on 9 September 2025].
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With her partnership in Equity Law Firm having been established, one of its main clients, currently
listed first on its website, is the State Oil Company of the Azerbaijan Republic (SOCAR)32
.
SOCAR is the national oil and gas company of Azerbaijan. The sole shareholder is the
Government of the Republic of Azerbaijan3334. The state's absolute control is demonstrated by
the fact that SOCAR's senior management is appointed directly by the President of Azerbaijan35
.
In fact, the current President of Azerbaijan, Ilham Aliyev, together with his father, the former
president of the country, Heydar Aliyev, and the president's wife, Mehriban Aliyeva, are all listed
together on the website's “home” page as leaders of the public company. The current President of
Azerbaijan is indeed the president of SOCAR – after having previously held the role of Vice
President of SOCAR from 1994 to 200336 while waiting to inherit executive power from his father.
32 Equity Law Firm, Projects. The website has been archived: Archive 1, Archive 2 [consulted and archived on 9
September 2025].
33 State Oil Company of the Azerbaijan Republic (SOCAR), Home. Official website in Azerbaijani. The website has
been archived: Archive 1, Archive 2 [consulted and archived on 17 September 2025].
34 State Oil Company of the Azerbaijan Republic (SOCAR), Home. Official website in English. The website has been
archived: Archive 1, Archive 2 [consulted and archived on 17 September 2025].
35 President of the Republic of Azerbaijan, The Order of the President of the Republic of Azerbaijan On appointing
Rovshan Chingiz oglu Najaf as President of the State Oil Company of the Azerbaijan Republic, 21 July 2022.
36 State Oil Company of the Azerbaijan Republic (SOCAR), “The President”, Official website. The website has
been archived: Archive 1, Archive 2 [consulted and archived on 17 September 2025].
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A direct financial connection exists between Dr. Yudkivska and Mr. Malinevsky: They are listed
as equal financial partners (50/50) in War Damage Institute LLC, sharing profits, losses, and
decision-making equally. Malinevsky holds a 20% stake in the Equity legal structure and
personally benefits from Equity’s profits, including those from representing SOCAR. Beyond the
fact that Dr. Yudkivska is a partner at Equity, the Ukrainian law firm representing SOCAR, through
the separate joint venture (War Damage Institute), it is reasonable to infer that Yudkivska's
financial interests are indirectly supported by Equity’s client relationships.
This indirect financial dependence raises an additional legitimate concern about her impartiality.
Equity Legal Firm’s website clearly indicates that the firm represented SOCAR in multiple cases
before Ukrainian courts, specifically before the Northern Commercial Court of Appeal and the
Supreme Court37. Once more, in case the website is modified or the information changed, archives
of the website have been made.
37 Equity Law Firm, EQUITY's attorneys achieved a significant victory for the SOCAR gas station chain! The website
has been archived: Archive 1, Archive 2 [consulted and archived on 9 September 2025].
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From 2021 to 2023, Equity Law Firm successfully represented the Azerbaijani state-owned
company SOCAR in a major Ukrainian antitrust case. The dispute centered on a fine of
approximately 560,000 € imposed by Ukraine's Antimonopoly Committee (AMCU), which
accused SOCAR and other retailers (WOG and OKKO) of illegal coordinated pricing in 2017.
After the proceedings were dismissed and then revived twice by the Supreme Court, Equity Law
Firm ultimately won the case in March 2023. The Supreme Court upheld a ruling that AMCU's
market analysis was incomplete and that there were no legal grounds to hold SOCAR liable,
resulting in the fine being lifted.
Mrs. Yudkivska did not reveal her employment with a law firm representing Azerbaijan's main
state-owned company, establishing a direct economic link between the mandate-holder and the
Azerbaijani government involved in the proceedings. She also did not invoke Article 5 of the
Working Group on Arbitrary Detention's Methods of Work, which would have allowed her to
abstain from participating in the opinion on Ruben Vardanyan vs Azerbaijan, where a clear conflict
of interest existed.
III.2.- In cases involving the Russian Federation, Ganna Yudkivska systematically abstains
from participating: a Ukrainian citizen, she is also co-founder and owner of the War Damage
Institute LLC, a Ukrainian legal office linked to Equity Law Firm, focused on actions to
address damage caused by the Russian invasion. However in this case, which involved a
Russian national until 2022, Ruben Vardanyan, whom Ukraine has sanctioned, the mandate-
holder did not abstain from participating.
Ganna Yudkivska had previously invoked art. 5 of the Methods of Work of the Working Group
on Arbitrary Detention to abstain from participating in cases involving the Russian Federation.
Ganna Yudkivska recently abstained from participating in two Opinions involving Russia (Opinion
No. 76/2023 concerning Alexy Moskalev (Russian Federation and Belarus), and Opinion No.
11/2024 concerning Evan Gershkovich (Russian Federation)). Although the reason is not explicitly
stated, these cases reference Article 5 of the Methods of Work of the Working Group on Arbitrary
Detention, which pertains to the proper conduct a mandate-holder must adopt when faced with a
conflict of interest.
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Ruben Vardanyan was a Russian citizen until 2022, when he became an Armenian citizen and
moved to Nagorno Karabakh. Ruben Vardanyan was sanctioned by Ukraine on 19 October
2022 (Decree 726/2022, appendix 1, position 78338), regarding his alleged links with Russian
authorities. Ukraine is the only country to have sanctioned Mr. Vardanyan worldwide.
In October 2022, the President of Ukraine issued Decree 726/2022 Appendix 1, item 783,
implementing the National Security and Defense Council of Ukraine's decision to impose specific
sanctions on Ruben Vardanyan.39 The conflict arises not because Dr. Yudkivska herself sanctioned
Vardanyan, but because her State of nationality formally designated him for considering him an
enemy and supporting actions that undermine or threaten the territorial integrity, sovereignty and
independence of Ukraine reinforces the conflict of interest.40
It is worth noting that, according to open source information, the only country sanctioning Ruben
Vardanyan is Ukraine.41
Since Ukraine is at war with Russia and as a Ukrainian citizen, Dr. Yudkivska, following her
previous decisions, should have abstained from involvement in a case concerning a person
sanctioned by Ukraine for connections with Russia.
Moreover, Ganna Yudkivska is supposedly working as a lawyer supporting Ukrainian citizens
and/or State interests during the war. She established a legal office on 18 February 2025 to handle
war-related damages, the War Damage Institute LLC. Ganna Yudkivska is a co-founder, owner,
38 National Security and Defense Council of Ukraine, Ruben Vardanyan ́s sanction by Ukraine under Decree 726/2022,
appendix 1, position 783. [consulted and archived on 18 September 2025].
39 See Sanction ID: 22072611100783 at National Security and Defense Council of Ukraine
https://drs.nsdc.gov.ua/subjects?searchQuery=ruben%20vardanyan
40 Black Sea Caspia report. Link [consulte don 14 September 2025]
41 Open Sanctions, last accessed 7 September 2025. https://www.opensanctions.org/entities/Q4103721/
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and beneficiary in equal shares of the War Damage Institute LLC. with Oleh Malinevsky, who is
also a co-owner and managing partner of Equity Law Firm. They both registered War Damage
Institute LLC at the same address as Equity Law Firm (01001, Kyiv city, Rylskyi lane, 4). It is
worth noting that there is no website for this Institute, which would suggest that it does not want
to be known.
However, in the case concerning Ruben Vardanyan v. Azerbaijan, Ganna Yudkivska did not invoke
that Ukraine had imposed sanctions on him because of alleged Russian links, or her own
professional interests in the Russian-Ukrainian conflict as she had done in previous cases involving
the Russian Federation under Article 5 of the Methods of Work of the Working Group on Arbitrary
Detention.
III.3.- Her husband, Georgii Logvynskyi, a former Ukrainian politician, is reported to have
strong and direct political ties to Azerbaijan, such as an Azerbaijani origin and close
connections with Azerbaijan authorities.
Apart from the conflicts of interest previously noted, which include a direct financial relationship
with the Azerbaijani government and Mrs. Yudkivska's previous abstention from participation in
cases involving the Russian Federation, the fact that her husband, Georgii Logvinsky, has
Azerbaijani roots accentuates the issue at hand. Furthermore, publicly available reports detail
Logvinsky’s strong connections to Azerbaijani politics.
Georgii Logvynskyi served in the Verkhovna Rada (Ukrainian Parliament) from 2014 to 2019 as
a member of the People’s Front party42. He is currently under criminal investigation and the subject
of an arrest warrant issued by Ukraine’s National Anti-Corruption Bureau (NABU) in connection
with an alleged corruption scheme involving the company Zolotyy Mandaryn Oyl Tov. This
corruption case is linked to the payment of 54 million Ukrainian hryvnias from the Ukrainian state
to Zolotyy Mandaryn Oyl Tov in the context of a case before the European Court of Human Rights
(ECHR),43 where Mrs. Yudkivska acted as a judge between June 2010 and June 2022.44 The
investigation into this corruption was significantly obstructed by Georgii Logvynskyi's immunity,
which he held due to his wife, Ganna Yudkivska, who was a sitting judge at the ECHR at the time
the case was filed. Notably, Equity Law Firm—the same firm where Ganna Yudkivska is a partner
and which represents SOCAR—is representing Logvynskyi in these proceedings45
.
42 Verkhovna Rada of Ukraine, Georgii Logvynskyi profile. The website has been archived: Archive 1, Archive 2
[consulted and archived on 18 September 2025].
43 ECHR, “ZOLOTYY MANDARYN OYL, TOV v. UKRAINE”, 9 July 2024. The website has been archived:
Archive 1, Archive 2. [consulted and archived on 15 September 2025].
44 European Court of Human Rights, https://www.echr.coe.int/w/ganna-yudkivska [consulted on 21 September 2025].
45 Equity Law Firm, Projects – Logvinskiy. The website has been archived: Archive 1, Archive 2 [consulted and
archived on 11 September 2025].
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Georgii Logvynskyi was an active member of the Working Group on Interparliamentary Relations
of the Verkhovna Rada of Ukraine with Azerbaijan46, a working group formed to strengthen
bilateral relations between the Members of Parliament of both countries47. In February 2017, the
Working Group on Interparliamentary Relations of the Verkhovna Rada of Ukraine with
Azerbaijan, which included Logvynskyi, paid a visit to Azerbaijan at the invitation of Azerbaijani
Members of Parliament48
.
In the same vein, it is worth noting the participation of Georgii Logvynskyi, together with other
members of the Ukrainian Verkhovna Rada, in the ceremony held in Kiev in December 2016
dedicated to the 25th anniversary of Azerbaijan's state independence and the Solidarity Day of
World Azerbaijanis49
.
Logvynskyi has been described as “half-Azerbaijani” in public statements made in May 2022 by
Rovshan Taghiyev, Chairman of the “United Ukrainian Azerbaijanis Congress” (UKAU), in the
context of the Russian invasion of Ukraine which strengthened Logvynskyi’s personal and political
ties to Azerbaijan government50
. In September 2017, Logvynskyi was also a participant at the
“Congress of European Azerbaijanis” held in Kiev51
.
Details on his Azerbaijani origins were unveiled in January 2017, when Logvynskyi granted an
interview to the Azerbaijani media outlet AzVision.az following his election as Vice-President of
46 Mi.Рейтинги, “Georgiy Logvynskyi”, 16 September 2023. The website has been archived: Archive 1, Archive 2
[consulted and archived on 15 September 2025].
47 Ministry of Foreign Affairs. Republic of Azerbaijan, “Bilateral diplomatic relations between the Republic of
Azerbaijan and Ukraine”. The website has been archived: Archive 1, Archive 2 [consulted and archived on 15
September 2025].
48 Olaylar, “Azerbaijan-Ukraine interparliamentary relations are expanding further”, 23 February 2017. The website
has been archived: Archive 1, Archive 2 [consulted and archived on 15 September 2025].
49 Republic of Azerbaijan, Embassy in Ukraine, “Kiyev şəhərində Azərbaycanın dövlət müstəqilliyinin 25-ci
ildönümünə və Dünya Azərbaycanlılarının Həmrəylik Gününə həsr olunmuş təntənəli tədbir keçirilib”, 20 December
2016. The website has been archived: Archive 1, Archive 2. [consulted and archived on 16 September 2025].
50 Azerbaycan24, “Diaspora head: Thousands of Azerbaijanis fighting for territorial integrity of Ukraine”, 23 May
2022. The website has been archived: Archive 1, Archive 2 [consulted and archived on 15 September 2025].
51 Atributinfo, “A meeting of the Congress of European Azerbaijanis was held in Kiev”, 13 September 2017. The
website has been archived: Archive 1 [consulted and archived on 15 September 2025].
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PACE, revealing that his father was born in Goychay, Azerbaijan, and subsequently relocated to
Kiev, Ukraine's capital.52
In the same interview with the Azerbaijani media outlet Logvynskyi admitted to being friends with
Sabir Hajiyev, a member of the Azerbaijani parliament elected precisely from the Goychay region.
He also confessed to being friends with the then head of the Azerbaijani delegation to the PACE
(Samad Seyidov) and former MP Aydin Abbasov, noting that he maintained close contact with
members of the Azerbaijani diaspora in Ukraine.
He further claimed, regarding his Azeri origin, that “Azerbaijan is always in my heart” (literally
“l’Azerbaïdjan est toujours dans mon coeur”). Moreover, he unequivocally declared before the
Azerbaijani media outlet that “without a doubt, Nagorno-Karabakh is an integral part of
Azerbaijan”53
. Ruben Vardanyan was detained for his role protecting Nagorno-Karabakh.
Logvinsky has held key international roles, serving as Vice President of PACE from 2017 to 2018
and Vice President of the European People’s Party faction in PACE from 2015 to 2019. Notably,
Logvynskyi's time at PACE, from 2015 to 2019, coincides with the exposure of the “Azerbaijani
Laundromat," a scheme that used $2.9 billion to bribe politicians, gain support, and block critical
resolutions on human rights violations in Azerbaijan, including the Strasser report from 2013 on
political prisoners in Azerbaijan.54
Although Logvynskyi was not explicitly named in the 2018 report by the Independent Expert Body
investigating Azerbaijani bribery at PACE, his direct involvement with PACE immediately after
the corruption scheme—during the ongoing investigation—along with his publicly-disclosed
connections to Azerbaijani interests, raises concerns about broader patterns of political closeness
and influence.
52 AzVision.az, “Vice-président de l`APCE: «l`Azerbaïdjan est toujours dans mon coeur» – EXCLUSIVE”, 26 January
2017. The website has been archived: Archive 1, Archive 2. [consulted and archived on 16 September 2025].
53 AzVision.az, “Vice-président de l`APCE: «l`Azerbaïdjan est toujours dans mon coeur» – EXCLUSIVE”, 26 January
2017. The website has been archived: Archive 1, Archive 2. [consulted and archived on 16 September 2025].
54 Organized Crime and Corruption Reporting Project (OCCRP), “Former German Lawmakers on Trial over Alleged
Bribes from Azerbaijan”, 10 January 2024. The website has been archived: Archive 1, Archive 2. [consulted on 18
September 2025].
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According to Azerbaijani media outlets, while Logvinsky served as Vice President of PACE in
2019, he stated, “Azerbaijan is a model country in terms of stability and public order in comparison
with a number of European countries, not just in the region”.
The PACE investigation into the corruption scheme was preceded by the European Stability
Initiative's inquiry into the “Caviar Diplomacy” (2012 and 2016)55 and the Organized Crime and
Corruption Reporting Project investigation (2017) which led to: i) The expulsion of 13 PACE
members, ii) The conviction of Italian MP Luca Volontè in Milan for accepting bribes from
Azerbaijani interests, iii) A criminal investigation of three German Bundestag members and PACE
delegates, and iv) Azerbaijan’s suspension of credentials at PACE.
On 25 January 2024, PACE voted not to ratify the credentials of Azerbaijan's parliamentary
delegation due to concerns about the lack of free and fair elections, weak separation of powers,
judicial independence, and human rights violations, including the situation in Nagorno-
Karabakh56. The text of the approved resolution added that the delegation of Azerbaijan could
“resume its activities in the Assembly when conditions provided by the Rules of Procedure are
met”.57 In response to this resolution, Azerbaijani delegation suspended its work at the PACE58
.
As stated on the PACE website “the Parliament of Azerbaijan did not transmit credentials for the
2025 Ordinary Session”59
.
Moreover, the Head of SOCAR Representative Office in Ukraine, Elchin Mammadov, is
mentioned in the “Report of the Independent Investigation Body on the allegations of corruption
55 European Stability Initiative (ESI), “Caviar Diplomacy — How Azerbaijan silenced the Council of Europe”, 24
May 2012. The website has been archived: Archive 1, Archive 2 [consulted and archived on 18 September 2025].
56 Parliamentary Assembly of the Council of Europe (PACE), “PACE resolves not to ratify the credentials of
Azerbaijan’s parliamentary delegation, citing a failure to fulfil ‘major commitments’”, 25 January 2024. The website
has been archived: Archive 1, Archive 2 [consulted and archived on 15 September 2025].
57 Parliamentary Assembly of the Council of Europe (PACE), “Challenge, on substantive grounds, of the still
unratified credentials of the parliamentary delegation of Azerbaijan”, 23 January 2024. The website has been
archived: Archive 1 [consulted on 15 September 2025].
58 The Milli Majlis of the Republic of Azerbaijan, “Statement by Parliamentary Delegation of Azerbaijan to
Parliamentary Assembly of Council of Europe”, 24 January 2024. The website has been archived: Archive 1, Archive
2 [consulted and archived on 15 September 2025].
59 The Milli Majlis of the Republic of Azerbaijan, “Azerbaijan”. The website has been archived: Archive 1 [consulted
and archived on 15 September 2025].
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within the Parliamentary Assembly” issued on 15 April 2018. According to the report, the
Ukrainian deputy in the PACE, Volodymyr Ariev, “had been the subject of a corruptive offer made
by the president of SOCAR Ukraine, Mr Elchin Mammadov, aimed at securing Mr Agramunt’s
appointment to the position of EPP President”. Following the description of events contained in
the report, Mr. Ariev “was approached by Mr Elchin Mammadov, the president of SOCAR
Ukraine, the local Ukrainian branch of the Azerbaijani State oil company, and offered “any
assistance needed” if he would support Mr Agramunt for the position of EPP President. Mr Elchin
Mammadov had indicated that he was acting on the basis of orders given by a higher authority”60
.
Currently, Elchin Mammadov continues to hold the position of Head of SOCAR Representative
Office in Ukraine.
61
One of Elchin Mammadov's brothers is Gunduz Mammadov, who, according to the sources
consulted, held the position of Deputy Prosecutor General of Ukraine between October 2019
and July 202162
. According to open sources consulted, Gunduz Mammadov (brother of Elchin
Mammadov, Head of SOCAR Representative Office in Ukraine) worked alongside Georgii
Logvynskyi in drafting the Report of the International Expert Group on the events that took place
near the Verkhovna Rada of Crimea in February 2014.
In the following image63, Georgii Logvynskyi and Gunduz Mammadov can be seen together at the
presentation of the report on 23 February 2017. On that date, Gunduz Mameddov was Prosecutor
of the Autonomous Republic of Crimea.
In conclusion, all the facts outlined above confirm that Logvynskyi has Azerbaijani roots through
his father, who was born in Goychay (Azerbaijan). He was a member of the “Working Group on
Interparliamentary Relations of the Verkhovna Rada of Ukraine with Azerbaijan,” participated in
the “Congress of European Azerbaijanis,” and was actively involved in events organized by
60 PACE, Communication.
61 KPMG, Ukrainian Business Leaders Outlook 2021, page 20.
62 FED.AZ, Neft Fondunun direktorunun qardaşları: Nazir müşaviri, Baş prokurorun müavini və SOCAR… FOTO, 10
December 2019.
63 Yhiah, Refat Chubarov, George Logvinsky and Mustafa Dzhemilev, 23 February 2017.
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Azerbaijan. In fact, Ganna Yudkivska's husband clearly stated that “Azerbaijan is always in my
heart” (literally “l’Azerbaïdjan est toujours dans mon coeur”) because of his Azeri heritage.
Furthermore, he stated before an Azerbaijani media outlet that “without a doubt, Nagorno-
Karabakh is an integral part of Azerbaijan.” 64
It is also worth noting that in 2015, Mrs. Yudkivska visited Azerbaijan one month before issuing
her concurring opinion in the case of Sargsyan vs. Azerbaijan before the ECHR. Indeed, in May
2015, Ganna Yudkivska participated in an international conference held in Baku, dedicated to the
10th anniversary of the Judicial Legal Council of Azerbaijan (“International Conference Devoted
to the 10th Anniversary of the Judicial Legal Council on ‘The Role of the Judiciary in the
Democratic Society’”). During the event, she was photographed in the “museum dedicated to the
history of justice and the role of National Leader Heydar Aliyev [father of the actual President of
the Republic of Azerbaijan] in the creation of a modern judicial system”65
.
III.4.- Summary of facts
• Primarily, Hanna Yudkivska is a lawyer and active partner at Equity Law Firm, which offers
legal services and representation for the State Oil Company of the Azerbaijan Republic
(SOCAR). This establishes a direct link between her and the Azerbaijani Government, a party
to Opinion 46/2024 proceedings, and potentially a financial link as well if as is ordinary
practice in law firms, she is compensated as a partner from pooled profits across all the law
firm’s clients.
• In previous cases involving the Russian Federation, Ganna Yudkivska refrained from
participating. However, she joined a WGAD opinion concerning Ruben Vardanyan, who was
64 AzVision.az, “Vice-président de l`APCE: «l`Azerbaïdjan est toujours dans mon coeur» – EXCLUSIVE”, 26 January
2017. The website has been archived: Archive 1, Archive 2.
65 Ministry of Justice of the Republic of Azerbaijan, “International Conference Devoted to the 10th Anniversary of the
Judicial Legal Council on ‘The Role of the Judiciary in the Democratic Society”, May, 2015. The website has been
archived: Archive 1, Archive 2 [consulted and archived on 10 September 2025].
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sanctioned by Ukraine for his alleged ties to Russia. Additionally, Mrs. Yudkivska is the co-
founder and co-owner of the War Damage Institute LLC, a Ukrainian legal firm associated
with Equity Law Firm, sharing the same address and one of the owners. This organization
reportedly focuses on addressing damage in Ukraine caused by Russia invasion.
• Finally, Ganna Yudkivska’s husband, a former Ukrainian politician who is subject to an arrest
warrant for corruption related to a case at the ECHR (when Yudkivska was a judge there), is
reported to have strong personal and political ties to Azerbaijan, including being “half
Azerbaijani” because his father was born in Azerbaijan.
The direct economic link between Ganna Yudkivska and the Government of Azerbaijan, her
nationality and professional ties to the Russia-Ukraine conflict, as well as her husband's close
personal and political connection to Azerbaijan represent a substantial conflict of interest
questioning the impartiality and independence of this member of the WGAD in the deliberation
involving Ruben Vardanyan’s case against Azerbaijan.
IV. APPLICABLE FRAMEWORK AND BREACHES OF REGULATIONS
IV.1. Applicable framework of regulations guiding the WGAD mandate
In Resolution 60/251 of 15 March 2006, entitled “Human Rights Council” (A/RES/60/251),
the UN General Assembly, “recognizing […] the importance of ensuring universality, objectivity
and non-selectivity in the consideration of human rights issues, and the elimination of double
standards and politicization”, stated the following:
“4. Decides further that the work of the Council shall be guided by the principles of
universality, impartiality, objectivity, and non-selectivity, constructive international
dialogue and cooperation, with a view to enhancing the promotion and protection of all
human rights, civil, political, economic, social and cultural rights, including the right to
development; […]
12. Decides also that the methods of work of the Council shall be transparent, fair and
impartial […]”.
Resolution 5/1 of the Human Rights Council, “Institution-building of the United Nations
Human” (A/HRC/RES/5/1) adopted on 18 June 2007, focuses on independence, impartiality and
personal integrity as key conditions to the appointment of mandate-holders:
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“39. The following general criteria will be of paramount importance while nominating,
selecting and appointing mandate-holders: (a) expertise; (b) experience in the field of the
mandate; (c) independence; (d) impartiality; (e) personal integrity; and (f) objectivity”.
The Manual of Operations of the Special Procedures of the Human Rights Council as
modified during the 15th Annual Meeting of Special Procedures in June 2008 similarly states the
need for mandate-holders to uphold the utmost independence throughout the execution of their
mission:
“11. Mandate-holders are selected on the basis of their expertise and experience in the area
of the mandate, personal integrity, independence and impartiality and objectivity. The
independent status of the mandate-holders is crucial in order to enable them to fulfill their
functions in all impartiality”.
The Code of Conduct for Special Procedures Mandate-holders of the Human Rights Council
(A/HRC/RES/5/2) provides a comprehensive set of obligations for mandate-holders in Article
3(a):
“Act in an independent capacity, and exercise their functions in accordance with their
mandate, through a professional, impartial assessment of facts based on internationally
recognized human rights standards, and free from any kind of extraneous influence,
incitement, pressure, threat or interference, either direct or indirect, on the part of any party,
whether stakeholder or not, for any reason whatsoever, the notion of independence being
linked to the status of mandate-holders, and to their freedom to assess the human rights
questions that they are called upon to examine under their mandate”.
The Code of Conduct for Special Procedures Mandate-holders of the Human Rights Council
(A/HRC/RES/5/2) further establishes that mandate-holders must:
“[f]ocus exclusively on the implementation of their mandate, constantly keeping in mind
the fundamental obligations of truthfulness, loyalty and independence pertaining to their
mandate” (Art. 3(d))
“[u]phold the highest standards of efficiency, competence and integrity, meaning, in
particular, though not exclusively, probity, impartiality, equity, honesty and good faith”
(Art. 3(e))
Article 3 of the Code of Conduct for Special Procedures Mandate-holders of the Human
Rights Council (A/HRC/RES/5/2) also prohibits mandate-holders from accepting any instructions
from governments or other actors in their resolution of cases submitted before them, commanding
them to:
“[n]either seek nor accept instructions from any Government, individual, governmental or
non governmental organization or pressure group whatsoever” (Art. 3(f)),
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“[r]efrain from using their office or knowledge gained from their functions for private gain,
financial or otherwise, or for the gain and/or detriment of any family member, close
associate, or third party” (Art. 3(i)),
“[n]ot accept any honour, decoration, favour, gift or remuneration from any governmental
or non governmental source for activities carried out in pursuit of his/her mandate” (Art.
3(j)).
In keeping with the obligations outlined in Article 3, Article 5 of the Code of Conduct for Special
Procedures Mandate-holders of the Human Rights Council (A/HRC/RES/5/2) establishes the
solemn declaration of mandate-holders as follows:
“I solemnly declare that I shall perform my duties and exercise my functions from a
completely impartial, loyal and conscientious standpoint, and truthfully, and that I shall
discharge these functions and regulate my conduct in a manner totally in keeping with the
terms of my mandate, the Charter of the United Nations, the interests of the United Nations,
and with the objective of promoting and protecting human rights, without seeking or
accepting any instruction from any other party whatsoever.”
Following Article 12(b) of the Code of Conduct for Special Procedures Mandate-holders of
the Human Rights Council (A/HRC/RES/5/2), mandate-holders must prevent personal affairs
from prejudicing the execution of their office, and thus:
“[…] show restraint, moderation and discretion so as not to undermine the recognition of
the independent nature of their mandate or the environment necessary to properly discharge
the said mandate”
Finally, Article 15 of the Code of Conduct for Special Procedures Mandate-holders of the
Human Rights Council (A/HRC/RES/5/2) establishes a provision for “accountability to the
Council” in case the mandate-holder breaches the Code of Conduct, which states that:
“In the fulfilment of their mandate, mandate-holders are accountable to the Council”.
As mentioned in Article 2.1 of the Code of Conduct for Special Procedures Mandate-holders
of the Human Rights Council (A/HRC/RES/5/2), the provisions of said code complement those
of the Regulations Governing the Status, Basic Rights and Duties of Officials other than
Secretariat Officials, and Experts on Mission (ST/SGB/2002/9) which were adopted by the
General Assembly in resolution 56/280 of 27 March 2002.
Article 3(c) of the aforementioned Code of Conduct states that mandate-holders must comply
with the Regulations Governing the Status, Basic Rights and Duties of Officials other than
Secretariat Officials, and Experts on Mission (ST/SGB/2002/9) as well as the Code of Conduct.
When a mandate-holder is faced with an enduring conflict between the execution of their mandate
and a financial interest they refuse to dispose of, Regulation 2 (h) of the Regulations Governing
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the Status, Basic Rights and Duties of Officials other than Secretariat Officials, and Experts
on Mission (ST/SGB/2002/9) states a clear obligation of recusal from the case at hand:
“Officials and experts on mission shall not be actively associated with the management of,
or hold a financial interest in, any profit-making, business or other concern, if it were
possible for them or the profit-making, business or other concern to benefit from such
association or financial interest by reason of their position with the United Nations.
Officials or experts on mission who are in such a situation shall either dispose of that
financial interest or formally excuse themselves from participating with regard to any
involvement in that matter that has given rise to the conflict-of-interest situation”.
Regulation 3 of the Regulations Governing the Status, Basic Rights and Duties of Officials
other than Secretariat Officials, and Experts on Mission (ST/SGB/2002/9) further states:
“Officials and experts on mission are accountable to the United Nations for the proper
discharge of their functions.”
Additionally, the Methods of work of the Working Group on Arbitrary Detention
(A/HRC/36/38) in its Paragraph 5 establishes in more general terms:
“When the case under consideration or the country visit concerns a country of which one
of the members of the Working Group is a national, or in other situations where there may
be a conflict of interest, that member shall not participate in the discussion of the case,
in the visit or in the preparation of the report on the visit”.
There is no formally codified procedure within the Code of Conduct for seeking the recusal of a
mandate-holder from a specific case. However, if concerns arise that a member of the WGAD has
failed to uphold proper conduct, individuals or groups may raise these concerns before the UN
Human Rights Council or through the Coordination Committee of Special Procedures—a body
composed of elected mandate-holders overseeing coordination, working methods, and ethical
standards across the system.
As laid forward in the Manual of Operations of the Special Procedures of the Human Rights
Council as modified during the 15th Annual Meeting of Special Procedures in June 2008, the
Coordination Committee is tasked with “enhancing the effectiveness of and independence of
mandate-holders”.
The Coordination Committee has a key role to play in dealing with the issue of conflicts of interest,
which constituted one of the main issues raised before the regulatory body in 2024 according to
the report on Activities of special rapporteurs, independent experts and working groups of
the special procedures of the Human Rights Council undertaken in 2024 (A/HRC/58/70)66
.
66 Activities of special rapporteurs, independent experts and working groups of the special procedures of the Human
Rights Council undertaken in 2024 (A/HRC/58/70), Office for the High Commissioner of Human Rights, 11 April
2025.
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In its letter to the President of the Human Rights Council dated 28 March 2025 pertaining to
the legal complaint alleging several ethical abuses committed by Special Rapporteur on
Palestine Francesca Albanese67
, the Coordination Committee recalled “the crucial importance of
avoiding real or perceived conflicts of interest”, and emphasized “that mandates holders should
exercise due diligence in assessing potential sponsorships from any organizations in a way that
does not result in real or perceived conflict of interest, taking into account the specificities of each
mandate”.
IV.2. Breaches of regulations
In the presence of an indisputable conflict of interest resulting from: (i) Hanna Yudkivska’s
economic and professional ties to Azerbaijan through the State Oil Company of the Azerbaijan
Republic (SOCAR), (ii) her Ukrainian nationality and professional ties to the Russia-Ukraine
conflict, which should have prohibited her from considering the case of a former Russian national
sanctioned by her country in a context of war, and finally (iii) her husband’s public support to
Azerbaijan policies in Nagorno-Karabakh, Ganna Yudkivska maintaining her participation in the
deliberation and adoption of Opinion No. 46/2024 constitutes a clear breach of all of the
aforementioned regulations, undermining the principles of impartiality, independence and
objectivity which must guide the WGAD mandate.
It should be noted that the mandate-holder has consistently refused to provide information on
external support received through other sources than OHCHR.
Indeed, the Coordination Committee oversees the disclosure by mandate-holders of external
support received through other sources than OHCHR in order to ensure full transparency about
funding received from all sources and to avoid real and perceived conflicts of interest. During the
22nd annual meeting of special rapporteurs/representatives, independent experts and working
groups of the special procedures of the Human Rights Council in 2015, mandate-holders:
“agreed on the need for greater transparency of external funding received in support of their
mandates, given that it might have an impact on the perception of their independence, and
decided to render disclosure of external funding received mandatory and make it publicly
available”68
.
However, in practice, such a declaration is not compulsory, but provided on a voluntary basis by
mandate holders to the Coordination Committee which includes the information collected in the
Special Procedures’ annual report.
67 Letter to the President of the Human Rights Council, Coordination Committee of Special Procedures, 28 March
2025.
68 Report of the 22nd annual meeting of special rapporteurs/representatives, independent experts and working groups
of the special procedures of the Human Rights Council (Geneva, 8-12 June 2015), including updated information on
the special procedures; A/HRC/31/39; 23 May 2016.
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According to the Facts and figures with regard to the special procedures in 2024
(A/HRC/58/70/Add.1)69
, in 2023 (A/HRC/55/69/Add.1)70
, and in 2022 (A/HRC/52/70/Add.1)71
,
Ganna Yudkivska has never provided any information to the Coordination Committee on external
support received through other sources than the OHCHR since her appointment to the WGAD (not
in 2022, 2023 or 2024).
Coincidentally, it is during her mandate that Ganna Yudkivska became a partner at Equity Law
Firm in September 2023, the law firm representing SOCAR, Azerbaijan’s national oil company.
At the same address as Equity Law Firm, the War Damage Institute LLC was co-founded by
Ganna Yudkivska in February of 2025, a legal office focused on actions to address damage caused
by the Russian invasion, and linked to Equity Law Firm (using the same address, co-owned by
Ganna Yudkivska and Oleh Malinevsky (co-owner and Managing Partner of Equity), although
without even a website).
Beyond these overlapping timelines, it is impossible to ascertain the financial influence of the
aforementioned companies on the execution of Ganna Yudkivska’s mandate, because the mandate-
holder refuses to provide information on any external support received since her appointment to
the WGAD in 2022.
Nevertheless, the mandate-holder was undoubtedly subject to extraneous influence in her
consideration of Ruben Vardanyan’s case, and may have been incited to reject his claims against
the Azerbaijan Republic —considering the State Party owns one of the biggest corporate clients
represented by her law firm. When participating in the deliberation and adoption of Opinion No.
46/2024, Ganna Yudkivska was therefore unable to act in an independent, impartial capacity as
dictated by Articles 3(a), 3(d) and 3(e) of the Code of Conduct for Special Procedures Mandate-
holders of the Human Rights Council (A/HRC/RES/5/2, Annex), and as reiterated in the solemn
declaration of mandate-holders laid out in Article 5 of the same Code.
69 Facts and figures with regard to the special procedures in 2024; A/HRC/58/70/Add.1; 20 March 2025.
70 Facts and figures with regard to the special procedures in 2023; A/HRC/55/69/Add.1; 21 March 2024.
71 Facts and figures with regard to the special procedures in 2022; A/HRC/52/70/Add.1; 22 March 2023.
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Equally, by refusing to disclose this conflict of interest and remove herself from the case
concerning Ruben Vardanyan, Ganna Yudkivska failed to comply with the obligation of
truthfulness outlined in Articles 3(d) and 5, the obligations of integrity, honesty and good faith
outlined in Article 3(e), and the obligation of restraint stated in Article 12(b) of the Code of
Conduct for Special Procedures Mandate-holders of the Human Rights Council
(A/HRC/RES/5/2, Annex).
Further, mandate holder Ganna Yudkivska openly violated the obligation to abstain explicitly laid
out in paragraph 5 of the Methods of work of the Working Group on Arbitrary Detention
(A/HRC/36/38) and in Regulation 2 (h) of the Regulations Governing the Status, Basic Rights
and Duties of Officials other than Secretariat Officials, and Experts on Mission
(ST/SGB/2002/9).
The documented abstentions by several mandate-holders, including Ganna Yudkivska in numerous
Russian-related cases, demonstrate that the mechanism is both known and used. Yet, her active
participation in the deliberation of the Ruben Vardanyan case—despite her Ukrainian nationality,
the sanctions imposed by her country, her firm’s legal ties to the Azerbaijani state and her spouse’s
origins and associations with Azeri politics —stands in contrast to these precedents.
The multi-faceted conflict of interest outlined above reasonably calls Ganna Yudkivska’s
impartiality into question when participating in the sensitive and politically charged detention case
concerning Ruben Vardanyan. These facts also raise serious concerns about the adequacy of
institutional safeguards, transparency obligations, and the enforcement of the UN Special
Procedures Code of Conduct and Regulations. These concerns legitimately extend to future cases
involving Armenian detainees or political dissidents brought before the Working Group against
Azerbaijan, particularly in light of ongoing tensions between Armenia and Azerbaijan.
As stated in Article 15 of the Code of Conduct for Special Procedures Mandate-holders of the
Human Rights Council (A/HRC/RES/5/2, Annex), and Regulation 3 of the Regulations
Governing the Status, Basic Rights and Duties of Officials other than Secretariat Officials,
and Experts on Mission (ST/SGB/2002/9), Gunna Yudkivska is accountable to the Council and
the United Nations in the fulfillment of her mandate, and for the breaches committed in the
execution of her mission.
The aforementioned circumstances merit closer examination and at a minimum justify future
disclosure and abstention from her involvement in any case brought against Azerbaijan to the
WGAD so as to preserve the integrity of its systems and processes.
V-. CONCLUSION
The circumstances outlined above provide strong reasons to believe that Dr. Ganna Yudkivska’s
participation in the WGAD’s consideration of Ruben Vardanyan v. Azerbaijan was in violation of
the Code of Conduct for Special Procedures Mandate-Holders and the WGAD’s Methods of Work.
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The sanctions imposed by Ukraine on Mr. Vardanyan create an appearance of bias, particularly in
light of her previous abstentions from cases involving Russian citizens. In addition, her role as a
partner in a Ukrainian law firm representing Azerbaijan’s state-owned oil company SOCAR, and
her co-ownership of a related legal entity with the firm’s managing partner, suggest financial and
professional ties that may reasonably call her impartiality into question.
Mandate Holder Yudkivska participation in the case of Ruben Vardanyan contravenes Articles 3(a),
3(d), 3(e), and 3(i) of the Code of Conduct, which mandate independence, impartiality, integrity,
and the prohibition of private gain, as well as Regulation 2(h) of ST/SGB/2002/9, which requires
recusal when financial interests overlap with United Nations functions. Her failure to disclose this
role or to abstain from related proceedings further constitutes a breach of Paragraph 5 of the
WGAD Methods of Work, which stipulates recusal in cases where conflicts of interest exist.
Mandate holder Yudkivska abstained from WGAD cases involving Russia (Moskalev and
Gershkovich), presumably on grounds of nationality and conflict of interest, in line with Paragraph
5 of the WGAD Methods of Work. Yet she did not abstain in Vardanyan’s case, despite stronger
grounds: Vardanyan was a Russian citizen until 2022, sanctioned by Ukraine, and her own law
firm represented Azerbaijani state interests. This selective application of recusal obligations
undermines impartiality, contrary to Article 3(a) and Article 5 of the Code of Conduct (duty of
impartiality and solemn declaration of independence).
Finally, Ms. Yudkivska’s should have abstained because of her personal connections with
Azerbaijan as well, in line with the abovementioned regulations. Her husband, Georgii
Logvynskyi, is a former Ukrainian Member of Parliament with longstanding connections to
Azerbaijan. His father was born in Azerbaijan, and Mr. Logvynskyi has identified himself as “half-
Azerbaijani.” He has also participated in interparliamentary groups with Azerbaijan and publicly
praised Azerbaijan as a “model country.” Mr. Logvynskyi is currently under criminal investigation
for corruption in Ukraine, and the law firm representing mandate holder Yudkivska is also
representing him. These personal relationships intensify concerns regarding potential bias.
According to Article 3(i) of the Code of Conduct, mandate-holders must refrain from permitting
family connections to generate conflicts of interest, and under Article 12(b), they must avoid
behavior that undermines the recognition of their independence.
By failing to disclose her professional connections to the Government of Azerbaijan, overlooking
her spouse's personal and political ties to Azerbaijan, and inconsistent application of recusal
standards, Mrs. Yudkivska breached her responsibilities under the Code of Conduct, WGAD
Methods of Work, and UN Regulations for Experts on Mission. These rules explicitly require
mandate-holders to avoid actual or perceived conflicts of interest and to recuse themselves when
impartiality might reasonably be questioned.
The confluence of professional and personal conflicts created a reasonable perception of bias,
which should have led Ganna Yudkivska to abstain from participating in Opinion No. 46/2024.
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source : B.F. , UN (United Ntions, ONU (Organisation des Nations Unies)