ESG Metric: Anti-corruption
Ease of implementation: Medium
Suitable for: All businesses
Suggested functional lead: HR, legal department
Summary
An anti-corruption policy can be created by following the template below and having it reviewed by your legal team. It is important to assign responsibility to a member of staff or department to execute this policy and keep it up to date. It is recommended to publish your policy internally so that all employees understand how it affects their ways of working. If possible, publish to policy externally to promote your company values and culture of transparency.
Background Information
Corruption is defined as “requesting, offering, giving or accepting directly or indirectly, a bribe or any other undue advantage or prospect thereof, which distorts the proper performance of any duty or behaviour required of the recipient of the bribe, the undue advantage or the prospect thereof”. Corruption and bribery are responsible for an average direct annual global cost of $3.6 trillion paid in bribes annually. Thus, anti-corruption legislations are being enforced more rigorously globally to ensure all business, whether private or public, are being held accountable. Notably, the Foreign Corrupt Practice in the US and Bribery Act in the UK are making companies more liable for the conduct of their employees and the actions of their intermediaries including agents, consultants and other external parties.
Implementation Steps
Assign responsibility
Assign responsibility to a member of staff from the legal department or Human Resources to create a draft policy.
Create a policy draft based on our template
The template should outline the following sections:
Your type of business
Requirements that must be adhered to
Regulatory background
Compliance strategy
Risk assessment
Gifts and benefits
Political and charitable donations
Due diligence
Reporting suspicions
Training
Record keeping
Annual review
Ensure the draft policy is reviewed
Ensure the draft is reviewed by a legal team or a legal expect to ensure it covers the required areas and follows any legislations specific to your areas of business and location.
Publish Anti-corruption Policy
Publish the anticorruption policy internally for employees to understand how it affects their ways of working. If possible, publish externally for potential employees or clients to see your commitment to anti-corruption and the transparent nature of your organisation.