This section provides guidance in relation to the writing and adoption by an organisation of an anti-corruption policy (measure 1 of the Anti-Corruption Programme).
There should be two parts to an organisation’s anti-corruption policy:
A commitment by the organisation to prohibit corruption.
A commitment by the organisation that it will implement measures to:
prevent corruption by, on behalf of, or against the organisation; and
detect, report and deal with any corruption which does occur.
Both parts are necessary. As with any management commitment, it would be insufficiently effective if management merely made a statement of intent (i.e. “we prohibit corruption”) but did nothing to follow through with it. Any statement of policy needs management measures to ensure as far as reasonable that the policy is put into effect and is complied with by personnel and business associates.
Anti-corruption measures designed both to prevent corruption, and to detect, report and deal with any corruption which occurs, are contained in measures 2 to 21 of the Anti-Corruption Programme.
The policy may be a separate policy dealing only with corruption. Alternatively, the organisation may issue a policy statement covering several topics, including, for example, corruption, health and safety, quality, protecting the environment, non-discrimination etc.
The organisation must adopt the policy. It is vital that there is the correct leadership and tone from the top, otherwise junior personnel will be less likely to comply. This adoption of the policy should be recorded. This could be by way of a board resolution in the case of an organisation with a board, or, in the case of an organisation owned and controlled by one person, by a signed resolution by that person.
See sample Anti-Corruption Policy.
See paragraph 1 of sample Resolution by the board to adopt the policy
Implementation checklist for Measure 1
- Board should agree to adopt an anti-corruption policy.
- Board should appoint a manager to write an anti-corruption policy (see sample Anti-Corruption Policy)
- Board should pass a resolution (at meeting or by signed resolution) (see paragraph 1 of sample Resolution) which agrees and records that the organisation will adopt the anti-corruption policy. [Note: This board resolution can deal at the same time with measures 1, 2, 3 and 5 of the Anti-Corruption Programme, or separate resolutions can be passed]
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Most recent update on 17th February 2016
Page first published on 12th April 2015
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