1. SummaryDownload report
The Open Dialogue Foundation (ODF), founded in 2009 in Poland, is a European NGO fighting for human rights, democracy and the rule of law in the post-Soviet area and, more recently, within the EU, focusing on stopping the rise of authoritarianism and the far-right in states like Poland and Hungary. Before 2017 the Foundation was known in Poland for its support delivered to Ukraine during the Euromaidan Revolution and in response to Russian aggression , , as well as advocating for INTERPOL reform and in defence of political persecution victims in the post-Soviet area.
Due to its activities, ODF’s leadership and activists are under constant attack by the states it opposes, most notably Kazakhstan, Russia, Moldova (until the fall of Vlad Plahotniuc’s regime) and since 2017 Poland. The authorities of these states and their supporters produce disinformation and trumped-up charges to silence the organisation and induce a chilling effect on civil society.
Since 2017, when the Foundation took a stance against the declining rule of law situation in Poland under the Law and Justice (PiS)-led government, a steady smear campaign, combined with legal and extralegal efforts, has been perpetrated by the ruling coalition and its supporters. The authorities attempted to silence the NGO by abusing Polish law (e.g. unsuccessfully attempting to replace the foundation’s board) and even the rules of EU institutions, trying to block ODF’s access to them.
In 2018, ODF’s President, Lyudmyla Kozlovska, was expelled from the EU by the Polish authorities, which abused the Schengen Information System for that reason. The fabricated charges against her were deemed politically motivated and baseless by 5 European states which disregarded the Polish entry ban, with Belgium granting her permanent residence. The charges were finally found groundless by Polish courts in 3 separate rulings.
In June 2021, ODF’s Chairman of the Supervisory Board and Kozlovska’s husband, activist Bartosz Kramek, was detained in Warsaw on the basis of fabricated charges and placed under 3-month pre-trial detention on the request of the politicised public prosecutor’s office. Kramek is persecuted by the ruling PiS party for purely political reasons. With intensive public support, after a group of citizens provided bail, Kramek was released, having spent 3 weeks in detention. During this time he was considered by many high-profile figures, including Nobel Peace Prize laureate Lech Wałęsa, one of the first political prisoners in post-communist Poland (the first being LGBT+ activist known as Margot).
2. Polish authorities’ persecution of ODF
Since 2017, when it first stood up against the Polish government’s assault on the independence of the judiciary, ODF, its representatives and associates have faced numerous attacks and smear campaigns from the authorities who sought to stop their watchdog activities. The recent persecution of Bartosz Kramek is a continuation of the unsuccessful attempts to shut down the Foundation [The detailed chronology how the pro-governmental ‘Law and Justice’(PiS) party launched a campaign of legal harassment and disinformation against the ODF, and personally Kozlovska and Kramek as leaders of the human rights organisation, described, up to late 2019, in this report – edit.], which began when he published a Facebook article in which he proposed steps for acts of civil disobedience which would help topple the Law and Justice (PiS) party’s increasingly authoritarian rule.
On 14 August 2018 Lyudmyla Kozlovska was expelled from the EU and after being a resident for over 10 years was refused a long-term permit to stay in Poland on politically motivated grounds. It was done on the basis of a never-disclosed, secret opinion issued by the Head of the Internal Security Agency (ABW), which concluded that Kozlovska was “a threat to Poland’s state security”. As a result Kozlovska was placed by the Polish authorities on the Schengen Information System blacklist. The content of the ABW file was later leaked to the press, which reported that the dossier was “based on publicly available internet sources and data from the Moldovan parliament’s report”, concluding that it was “embarrassing to the ABW”. The mentioned allegations from Moldova, contained in a report ordered personally by then de facto ruler, super-oligarch Vlad Plahotniuc, are described in the next chapter.
The Warsaw Voivodeship Administrative Court, which had access to the file, revoked the decision on Kozlovska’s inclusion and not extending her stay permit three times [None of the court decisions implemented as of yet – edit.]. The Court stated that the materials provided by the Internal Security Agency were “generic” and “were not reasonably based on the evidence gathered by the agency”. At the same time the Belgian government, together with Germany, Switzerland, France and the UK, disregarded the doubtful listing finding no substance to uphold the ban. What is more, adhering to the principle of the right to family life, Belgium went on to grant Kozlovska a 5-year residence permit which has allowed her to continue her advocacy work. Since 2018 Kramek, a Polish citizen, has been residing with Kozlovska in Brussels, Belgium.
Furthermore, as was revealed on 20 July 2021, on the day of Bartosz Kramek’s release (15 July) the prosecutor’s office issued an order banning him from leaving Poland, thus continuing its political persecution and further abusing power by separating the family of Bartosz Kramek and Lyudmyla Kozlovska, possibly in violation of European law (right for EU citizens and their family members to move and reside freely within the EU, i.e. Art. 21 TFEU, Directive 2004/38/EC or Art. 7 and Art. 33 of the Charter of Fundamental Rights of the EU) and Art. 8 of the European Convention on Human Rights.
3. Anti-ODF campaign by post-Soviet states
In addition to the more recent legal and extralegal persecution of ODF by the current Polish government, the NGO and its leadership has been frequently targeted by the post-Soviet states where it conducts its human rights defence work since 2009. These attacks are often gladly picked up by Polish pro-government media and ruling coalition politicians, who treat them as a confirmation of the reasoning behind their own persecution of ODF.
The most notable activities aimed at smearing the Foundation are steered by entities linked to the authorities of two states where ODF’s work had the most impact, Kazakhstan and the Moldovan government, back when the country was under de-facto control of the then-ruling Democratic Party leader Vladimir Plahotniuc. The peak of these attacks came in 2018-2019, though they have repercussions to this day and many of the known culprits are still at large – with those linked to Kazakhstan – following the fall of the Plahotniuc regime in Moldova – still occasionally producing new disinformation content.
Among the defamatory attacks with the strongest repercussions was a series of counterfeit documents and disinformation narratives re. ODF and its leaders (e.g. Kozlovska having a Russian passport, an investigation into ODF ongoing in Ukraine and multiple theories about links to the Kremlin or various oligarchs), all of which were promptly debunked by independent media , . Another attack, used by PiS as ammunition against opposition politicians in the 2019 European elections campaign, was an article in the Sunday Times smearing ODF on the basis of a Moldovan ‘parliamentary report’. The authors of the piece turned out to be PR professionals, and the report itself was quickly revealed to have been written on the personal request of oligarch Plahotniuc, with its accusations being dismissed as politically-motivated by the country’s prosecution service soon after Plahotniuc lost power.
A different, recurring angle of attack comes from Kazakhstan, with the Nazarbayev regime regularly slandering ODF whenever it supports the country’s opposition or defends human rights defenders and victims of political prosecution, most notably exiled opposition leader Mukhtar Ablyazov. Among the employed tactics are countless articles in suspicious or simply fake media outlets (and some in real ones receiving funding from Kazakhstani authorities), groups impersonating an EU body and even entire events organised solely for the purpose of defaming ODF. The organiser of the latter, former far-right UK Independence Party (UKIP) employee and Holocaust-denier Gary Cartwright, runs two blogs imitating EU media outlets (“EU Today” and “EU Reporter”), which focus in large part on praising Kazakhstan and attacking ODF, with hundreds of texts on the topic.
Many of the above smear attempts are re-used and amplified between the three states behind them, i.e. Kazakhstan, Moldova and Poland, each using them to justify its own persecution campaign.
4. Who is Bartosz Kramek
Bartosz Kramek was born on October 15, 1986, in Bystrzyca Klodzka, Poland. He gained his managerial education during his studies at the Faculty of Management and Social Communication at Jagiellonian University and the Leon Kozminski University in Poland.
Early in his career Kramek worked as Sales Director at Etendard Sp. z o.o. and Project Manager at the Inwestor TV web portal. He also worked in the sales department at TransmisjeOnline Sp. z o.o.. Later he established Silk Road Biuro Analiz i Informacji sp. z o.o. (SR). The company carried out analytical and advisory services, specialized in particular in risk assessments (including investment, image, and legislative risks) tied to the entry of foreign private sector entities into Eastern markets (Kazakhstan, Ukraine, and Moldova). Occasionally, the company provided consultancy on how to conduct business in the European Union (mainly for Ukrainian entrepreneurs), as well as seeking contractors and financing for investment projects, including in capital markets. The second branch of the company’s activities were services in the field of new technologies, primarily VOIP internet telecommunications and online streaming, in addition to, later on, software development and employee recruitment. Regular tax audits have not revealed any irregularities in SR’s activities. Among other instances, the activities of SR were described in an interview with Gazeta Wyborcza , , in 2017.
Kramek’s adventure with the NGO sector started in the Business Centre Club Student Forum foundation, where he coordinated a project focused on the development of entrepreneurship over the 20 years of free market economy in Poland. He then co-created the STARTER Foundation for Business Development and cooperated with the Management Observatory foundation, the Social Educational Society and others.
Kramek has supported the Open Dialogue Foundation since 2010 and has been the Chairman of its Supervisory Board since 2012. He was among the organisers of observation missions and support for Ukrainian civil society during Euromaidan at the turn of 2014. He was frequently a radio and television commentator covering Ukrainian affairs.
Since 2017 Kramek has been participating and sometimes leading numerous pro-democracy protests in Poland and became a columnist for the leading Polish daily, Gazeta Wyborcza. He is coordinating a campaign to combat the expansion of religious extremists in Europe, including the Kremlin-linked “Ordo Iuris Institute”, responsible for the abortion ban in Poland, “LGBT-free zones” & lobbying EU states for the withdrawal from the Istanbul Convention on preventing violence against women.
Bartosz Kramek was forced to move from Poland to Belgium after a politically motivated ban was imposed on his wife in August 2018. He regularly travels to Poland for various meetings, events and court hearings and is known for conducting a legal counter-attack against the PiS leadership and its cronies via 20 libel lawsuits. He is also fighting to preserve the independent judiciary and public prosecution service, supporting civic movements and activists. Kramek, together with ODF’s Vice-President Marcin Mycielski, has been co-organising or conducting high-level meetings with, among others, European Commission VP Věra Jourová, Justice Commissioner Didier Reynders, Equality Commissioner Helena Dalli numerous MEPs, U.S. senators’ and representatives’ offices, the U.S. State Department and NGOs in Washington, DC. Kramek and Mycielski are involved in collecting and providing data for official EU reports, PACE resolutions, reports by the UN and OSCE HDIM meetings. They authored public appeals to the European Commission regarding the rule of law situation in Poland, as well as an open letter to the remaining independent judges of the Polish Supreme Court.
In addition to his other endeavors Kramek launched and is coordinating the Brussels branch of the Homokomando pro-LGBT+ rights movement. Within their “Spontaneous Civic Campaign Headquarters” initiative Kramek, together with Mycielski, raised over PLN 540k ($147k) and installed 430+ pro-democracy & educational billboards throughout Poland in 2020 & 2021.
5. What is the Silk Road company
Silk Road Biuro Analiz i Informacji sp. z o.o. (SR) is an IT and consulting company owned by Bartosz Kramek. As part of its standard business operations, SR cooperated with multiple foreign entities, including clients based in Ukraine, Moldova, the UK, the US and overseas territories. Some of these utilised so-called virtual offices registered in Great Britain.
SR was one of the donors of the Open Dialogue Foundation, just as its leaders Lyudmyla Kozlovska and Bartosz Kramek were. All donations to ODF are subject to appropriate records and accounting procedures (as they constitute income to be spent on statutory activities). As a result, full transparency is maintained.
In addition, despite the fact that there is no legal obligation for NGOs in Poland to disclose their donors’ information, the Foundation has, for years, voluntarily disclosed the full list of donors in its financial reports, published annually and made available on our website. Naturally, this also applies to income from SR.
Kramek has also never hidden the fact that SR has financially aided the statutory work of the Foundation, the goal of which is to defend and promote the rule of law, human rights, and democracy in post-Soviet states. This model, known among Western NGOs, has, among other things, ensured our relative financial stability (which has allowed ODF to continuously carry out its mission), and ensured its independence from public sector funding.
In parallel to actions taken against the Foundation, SR became a target of the authorities’ persecution campaign. The actions of the public prosecution, Internal Security Agency (Polish: ABW) and fiscal authorities taken against SR included the harassment of SR’s co-workers and contractors by means of tax audits, interrogations or requests for statements.
6. Bartosz Kramek’s detention
On June 23rd, 2021, Bartosz Kramek was detained by the Polish security service (ABW) and within days placed under 3-month pre-trial detention upon the request of the public prosecutor’s office, which has long been politicised and fully controlled by Prosecutor General and Justice Minister Zbigniew Ziobro.
The timing of this arrest might have not been random – the Foundation had recently filed 20 lawsuits against the party’s leadership and cronies (already scoring wins against public broadcasters TVP & Polish Radio). It was also just about to launch its major project, a “Hall of Shame” platform with draft ‘indictments’ against the party leadership, its allies, prosecutors or even single police officers abusing their power when beating up protesters. The charges against Bartosz correspond to public allegations made against his wife – that is Silk Road and ODF being a money-laundering scheme and secretly working for foreign interests to destabilise Poland.
Although put on trial under the pretext of alleged financial crimes of his company, according to the over 110 Western, Polish and Ukrainian politicians, journalists and legal scholars and nearly 30 human rights organisations who signed a public appeal in his defence, Bartosz Kramek is in fact persecuted by the ruling Law and Justice (PiS) party for purely political reasons. The court provided for a bail of 300,000 PLN, with an appeal being submitted in regard to this decision by Marcin Kołodziejczyk of the Lublin regional prosecutor’s office. Due to a significant response from civil society, the entire bail was delivered by a group of activists, journalists and ordinary citizens. On July 15, 2021, the court rejected the prosecutor’s objection, freeing Kramek after 3 weeks in detention.
In addition to the earlier mentioned public appeal initiated by president Lech Wałęsa, in a letter sent on 2 August 2021 to Věra Jourová, Vice-president of the European Commission responsible for Values and Transparency, 10 Members of the European Parliament have expressed their support for Bartosz Kramek and their opposition to the politically motivated persecution carried out by the Polish government against him and ODF, as well as other civil society representatives.
7. Charges against Bartosz Kramek
The Public Prosecutor’s Office brought charges against Bartosz Kramek of “laundering money originating from the crime of false statement”. These charges, which carry a maximum penalty of 12 years of imprisonment, are based on the following assertions:
SR issued “fictitious invoices” for millions of Polish złoty (issuing false statements) – FALSE
The Prosecutor’s Office cites evidence in the form of “fictitious invoices” issued by SR and claims alarming, multi-million turnover, suggesting that this money was “laundered”. Below we break down the 5.3 million Polish złoty (for simplicity’s sake we will round up the numbers to whole ones) and explain what it was spent on.
According to the Prosecutor’s Office, from August 2012 to February 2016, the company issued 46 invoices for the sum of 5.3 million Polish złoty (or 1,173,001 euros, according to the exchange rate on June 25th, 2021). The charges, therefore, relate to a period of three and a half years, or 42 months. The average monthly income of the company was, therefore, approximately 126,190 Polish złoty, or 27,928 euros (which would be classified as a micro-enterprise under Polish law). The majority of the allegedly fictitious invoices pertain to the fact of collaboration with Ukrainian entrepreneur Petro Kozlovsky, Lyudmyla Kozlovska’s brother, and his business partners. He was also one the major individual donors to the Open Dialogue Foundation and became a primary target – falsely accused of shady business dealings and links to Russia – in the propaganda campaign instigated against it.
Between 2012 and 2016, the firm worked with a grand total of 46 people (including interns hired for several months for internships). The company paid all the taxes and fees it owed, including for all the aforementioned coworkers, so corporate tax, social and health insurance contributions and other required charges. In addition, the company incurred costs for work-related travel for employees, office spaces and supplies, cleaning services, translators, accounting, legal services etc. The company spent the bulk of its revenue on these recurring expenses.
In light of this, a question comes to mind: how much money from the national treasury, i.e. Polish taxpayers’ money, did the authorities spend on the proceedings against the activist and chairman of ODF’s Supervisory Board and his company, which have been ongoing since 2017? The Minister-Coordinator of the Secret Services, Mariusz Kamiński – preliminarily sentenced in the first instance for exceeding his powers and illegal operational activities – is known for spending state money on legally dubious operations (e.g. the case of so-called Agent Tomek). It is also telling that a company with an average monthly turnover of 126,190 Polish złoty (or 27,928 euros) – which, nota bene, qualifies it as a micro-business under the provisions of the “entrepreneurs’ rights” act – the state propaganda paints as an embezzler on a gigantic scale.
The allegations also refer to a period (particularly from 2015 to 2016) that was extremely financially difficult for ODF and SR and in which the Foundation’s energy was directed towards a wide range of assistance – including financial – to Ukrainian civil society after the Euromaidan Revolution. During this period, SR financially supported ODF, including through a debt incurred by SR from Bartosz Kramek and Lyudmyla Kozlovska (including her family), which remains partially unpaid to this day.
Revenue in SR’s accounts came from “fictitious” entities registered in tax havens (money laundering) – FALSE
The Public Prosecutor’s communiqués and state propaganda coverage are loaded with terms designed to evoke negative emotions in the audience, such as “tax havens”, “Panama Papers”, “illegal sources of income”, and “virtual offices”, furthermore suggesting that ODF and SR are financially linked to the Kremlin and thus constitutes a part of its hybrid warfare efforts against the West. In reality, these statements only contain hypotheses and speculations. These allegations are also identical to those which came from Moldova in 2018, then ruled by super-oligarch Vladimir Plahotniuc and which, in 2020, were dismissed in their entirety and deemed “political” both by the Moldovan Prosecutor-General as well as Polish courts (as pointed out by P. Pytlakowski from the Polityka weekly). Below we explain why these allegations do not relate to any illegal activities whatsoever, or are simply false.
Just as there are no laws which prohibit foundations from being funded by their leadership, there are no laws which prohibit doing business with companies registered in virtual offices in the United Kingdom (moreover, such offices are the norm in many industries, such as IT). Additionally, there are no laws which prohibit conducting business with firms registered in tax havens (a fairly common practice even for large companies).
The same is true of companies listed in the so-called Panama Papers – in which the information of over 200 thousand companies from all over the world are contained. The only thing they have in common is that they used the advisory services of what was once one of the largest financial advisory firms – Mossack Fonseca. Given the number of foreign contractors (mainly in the sector of new technology) that Bartosz Kramek’s company, Silk Road, has had over the years, it is not difficult to find at least one of each of the countries mentioned, let alone an entity included in the documentation (whatever that means) in the so-called Panama Papers (see more).
Finally, as we pointed out in our statement from the 23rd of June, the Prosecutor’s Office applies logic, or rather a lack of it, in a style typical of the rhetoric of the ruling Law and Justice party (PiS). Whereas, usually, taxpayers are charged with actions to the detriment of the state treasury, in the case of Bartosz’s company, the Prosecutor’s Office is questioning revenue on which taxes and other mandatory fees were properly paid. Previous tax audits (which have dragged on for years) have not revealed any irregularities in SR’s activities, meaning that the state treasury was the ultimate beneficiary of the alleged fraud.
8. Irregularities on the part of the authorities in Kramek’s case
Legal experts and practitioners, including the respected Warsaw prosecutor Ewa Wrzosek from the Lex Super Omnia association [Lex Super Omnia is the leading association of independent prosecutors critical towards the current ruling camp’s assault on the public prosecution service and independent judiciary – edit.], listed [Prosecutor Wrzosek’s analysis was submitted to ODF directly – edit.] numerous irregularities and violations regarding Kramek’s detention, charges he was presented with and related law enforcement activities:
- The arrest was conducted just one day after the entry into force of a new law strengthening the role of the prosecution service – giving it powers previously reserved for the court and limiting its transparency – as well as restricting the possibilities of posting bail by the suspect/accused. Only because of this law Bartosz had to remain in detention until the court of second instance ruled on the prosecution’s appeal.
These changes in the law are also emblematic of PiS’s general reform of the law enforcement and justice system. They are directed towards expanding the powers of the prosecution at the expense of the courts, as well as strengthening it in relation to the suspect/accused, as e.g. the suspect is sworn to secrecy while the prosecution can disclose any investigation details it sees fit whenever it suits their political agenda, invoking a vague definition of so-called public interest.
- Considering the investigation has been ongoing since 2017 and Bartosz has been present every time he was summoned by the court in every other legal proceeding, including other investigations concerning him or against him, his company and ODF, there was completely no reason for the detention and arrest. As far as the defence knows, no important new findings have been made and the charges concern actions which allegedly took place 5-9 years prior, so there was no rationale warranting the most serious restrictive measure.
There has been no instance of illegal interference with the investigation (e.g. by influencing the witnesses – over 100 hundred people have already been interrogated) either. The standard procedure would have been to just summon the person in order for the charges to be presented (although, according to the defence attorney, from the legal point of view it is difficult to justify why the charges and application for the pre-trial detention were brought at that time).
- The use of public resources was clearly disproportionate and unjustified – there were no rational or operational reasons to involve five high-level officers of the ABW (who rented a room next to Bartosz’s just in order to arrest him in the morning). None of the charges relate to state security and the prosecution did not explain how a small enterprise would be threatening it.
- The court was given around 35 minutes to get to know the case, which was supposedly contained in 40 volumes of files, before ruling on the detention. This was extended by 2h only to permit the defence attorney to reach the remote Lublin court in time from Warsaw, but the court did not have a chance to read the files in this period, as they had to simultaneously be read by another defence attorney already present at the scene.
- As it was revealed in the prosecution’s documentation, the money laundering charge was based only on the allegation of Bartosz Kramek’s company having issued VAT invoices for services which were allegedly not properly rendered, hence making them “false declarations” and the further use (“legalisation”) of funds received as payment for them automatically becoming “money laundering”. There are no charges of actual (“serious”) money laundering (like drug or arms trafficking, terrorism, embezzlement), as the supposedly laundered funds were all used up by the company’s and foundation’s (of which the company was an important donor) running costs.
- Contrary to the prosecutor’s claims, no funds have been “hidden” or dispersed to conceal their origin; it is difficult to imagine how it could be done by supporting ODF as a well-known NGO, dealing with politically sensitive matters and being an object of interest for the media as well as, in all likelihood, various intelligence and security services in Poland and abroad. ODF’s donors lists and financial reports are published on its website.
- The alleged crime seems to be damageless, with the state even being its beneficiary, as – if the charges were to be believed – invoices were issued by Bartosz Kramek’s company for services not actually rendered, but with all transactions registered and due taxes being paid. Furthermore, fiscal controls initiated in 2017 have not been finalised yet, being prolonged already over 10 times. Only once completed, lengthy administrative court proceedings are expected, making it then possible to respond to any potential findings. No private party has been damaged either. Also, there were no proceedings, nor accusations towards the company or foundation before the publication of Bartosz’s Facebook post on civil disobedience in July 2017.
- Prosecutor Marcin Kołodziejczyk, on whose orders Bartosz Kramek was detained, is a typical example of a PiS political nominee. Due to his promotions and awards in recent years, he was included in the list of ‘Kings of life’ in justice minister Zbigniew Ziobro’s prosecution in a 2019 report of the Lex Super Omnia association. His superior, regional prosecutor Jerzy Ziarkiewicz, who supervises the proceedings, is also Ziobro’s trusted associate. He is a member of the special team investigating Roman Giertych, having a parallel post in the National Prosecution Office. He supervised the investigations into the so-called hate affair in the Ministry of Justice and brought bogus charges against Jakub Karnowski, the former president of the Polish State Railways (PKP) for allegedly acting to the detriment of the company. A portrait of Lech Kaczyński – former president and late brother to PiS Chairman Jarosław – adorning his office serves as a symbol of his loyalties. Although the appropriate local jurisdiction for the Foundation and company would be the prosecutor’s office and courts in Warsaw, the case was referred to Lublin. It is already the third prosecutor’s office in the country which conducts this investigation – after the Warsaw district and regional ones.
- At every step of the proceedings, state and pro-government media have been receiving ample information on the case from the prosecution and ABW (spokesperson Stanisław Żaryn), clearly pointing to an orchestrated propaganda campaign, possibly designed to cover ongoing topics damaging to the PiS party (e.g. minister Dworczyk’s email leaks).
- The travel ban issued against Bartosz Kramek seems especially malicious, considering his wife’s continuing, unlawful Polish entry ban, with the forced separation potentially amounting to a violation of several EU laws and international treaties providing the right to family life, such as Art. 7 and 33 of the EU Charter of Fundamental Rights, Art. 8 of the European Convention on Human Rights and Directive 2005/38/EC.
- One theory, coming from a source within the Kazakhstani foreign ministry, argues that the Polish authorities might have struck a deal with their Kazakhstani counterparts, as just two weeks prior to the arrest, three Polish activists were released by Belarus following an intervention by Kazakhstan’s first president Nursultan Nazarbayev. It was revealed as part of an email leak that PM Morawiecki sees the difficult situation in Belarus as “political gold”, hence it wouldn’t be far-fetched for him to take steps against ODF – the leading international NGO fighting for human rights in Kazakhstan – in exchange for the dictator delivering a PR win to the Polish government.