This section provides guidance in relation to the requirement that the organisation should provide the resources needed to implement the anti-corruption programme (measure 6 of the Anti-Corruption Programme).
The extent to which resources are needed will depend on factors such as the size of the organisation, the nature of its operations, and the corruption risk it faces. Resources could include, for example:
Human resources: ensuring that sufficient personnel in the organisation are able to apply sufficient time to their relevant anti-corruption responsibilities so that the anti-corruption procedures can function effectively. This includes in particular ensuring that a compliance manager is appointed, and has sufficient time to undertake the compliance function. Other managers in other functions will need to have sufficient time to implement the procedures specific to their function.
Physical resources: ensuring that the necessary physical resources are made available in the organisation so that the anti-corruption procedures can function effectively. For example, office space, computer hardware and software, training materials, telephones, etc.
Financial resources: ensuring that a sufficient budget is made available so that the anti-corruption procedures can function effectively.
In smaller organisations with a relatively low corruption risk and a simple organisational structure, no additional resource may be necessary. Managers could take on the anti-corruption responsibilities within their functions and departments as part of their existing workload. For example:
The finance director may be appointed compliance manager and may also be made responsible for ensuring the effective operation of the anti-corruption aspects of the financial controls and internal audit. As the finance director may already as part of the finance function be responsible for general financial controls and internal audit, then adding the anti-corruption dimension to these aspects will not be a major addition of responsibility.
The procurement director may be made responsible for anti-corruption controls on the supply chain. As the procurement director may already as part of the procurement function be responsible for vetting the supply chain for adequate technical, quality, financial and programme suitability, and for appointing the suppliers on suitable contracts, then adding the anti-corruption dimension to the supply chain vetting, and ensuring the addition of an appropriate anti-corruption contract clause, will not be a major addition of responsibility.
The project director or commercial director may be made responsible for anti-corruption controls in relation to projects and contract implementation. As the project or commercial director may already as part of the project management or commercial function be responsible for ensuring performance of sub-contractors and other business associates under their contracts (e.g. for delivery, quantities, quality, timely performance etc.), then adding the anti-corruption dimension to project and commercial management will not be a major addition of responsibility.
The human resource / personnel director may be made responsible for ensuring that personnel are appropriately vetted, appointed and trained and that arrangements are in place for the reporting of any concerns. As this director may already be responsible for undertaking vetting of personnel for qualifications, experience etc., for general role-related training of personnel, and for a reporting facility on other issues (e.g. employment issues, safety etc.), then adding the anti-corruption dimension to these aspects will not be a major addition of responsibility.
Where organisations assess that existing managers cannot take on the full burden of the additional responsibilities within their existing scope, then it may be that they can do so if they are supported by some additional administrative or junior management resource.
Organisations which face a higher level of corruption risk and more complicated business structures may need to appoint additional senior personnel to take on or assist with these anti-corruption responsibilities.
All organisations will be different. The key point is that the organisation ensures that adequate resources are available to ensure that the anti-corruption procedures are implemented effectively.
Implementation checklist for Measure 6
- The organisation should assess what human, physical and financial resources are needed to implement the anti-corruption programme effectively.
- The organisation should ensure that these resources are made available.
Most recent update on 17th February 2016
Page first published on 24th November 2015
© 2016 GIACC