Companies, firms, professional institutions and government departments should develop anti-corruption rules for their officers, employees and members so that they are aware of the corrupt actions that are prohibited by the organisation, the consequences of corruption, and how to report corruption. These rules may form part of a general code of conduct, or may be issued separately. In the case of companies, firms and government departments, these rules should also be posted up in locations where they will be seen frequently by those officers and employees who are in positions where they may encounter corruption or where there is opportunity for corruption.
For further guidance see Gifts and Hospitality and Reporting
The following Sample Anti-Corruption Rules may be of use as a template.
Sample Anti-Corruption Rules
All officers and employees must comply with these rules. Breach of these rules may result in the following consequences:
- criminal conviction, which may result in fines and/or imprisonment;
- civil liability for compensation; and
- dismissal from employment, or other disciplinary action.
Personal safety: Do not comply with these Rules if you believe that, in doing so, you will endanger your personal safety or that of another person.
- You should act at all times honestly and without deception.
- You should not knowingly or recklessly do any of the following, or participate in any activity which involves any of the following:
- Offer, give, demand or accept any bribe or other improper advantage.
- Participate in any dishonest or deceptive activity, including in relation to any selection, certification, approval or management process.
- Provide, conceal, or approve work, materials, equipment or services which are not of the quality and quantity required under contract.
- Provide false, inaccurate or misleading information.
- Dishonestly withhold information.
- Make or submit false, inaccurate, misleading or exaggerated records, invoices, claims, applications for variations or extensions of time, or requests for payment.
- Dishonestly refuse or fail to approve, or delay in approving, work, materials, equipment, services, invoices, claims, applications for variations or extensions of time, or requests for payment.
- Dishonestly refuse or fail to pay, or delay in paying, sums due.
- If you are a director or officer of, or have any management responsibility for, [name of organisation], then in addition to the above, you must act as follows:
- Do not instruct, authorise or condone, expressly or impliedly, any corrupt activity.
- Make proper enquiries regarding any suspicion of corruption of which you become aware.
- Take reasonable preventive measures to stop corruption for which [name of organisation] may be liable.
- Report any suspicion of corruption to the board of directors and to the officer responsible for compliance with [name of organisation’s] anti-corruption programme.
You must not, directly or indirectly, and whether in your personal capacity or on behalf of [name of organisation]:
solicit any gift or hospitality in the course of your employment;
offer or give to, or receive from, any Connected Person any of the following:
a personal or corporate gift in excess of a value of […………….];
hospitality in excess of a value of […………….];
offer or give a donation, in excess of a value of […………….], to any political, charitable, or not-for-profit organisation, where a trustee, manager or beneficiary of that organisation is a Connected Person, or is related to a Connected Person.
offer, give, or receive any gift or hospitality which is in breach of the applicable law.
A “Connected Person” means any organisation or individual (other than an officer or employee of [name of organisation]) who has had, has, or may have any connection with or influence over the business of [name of organisation].
- You must enter in the Benefits Register details of all gifts and hospitality given or accepted by you. These details must be entered in the Benefits Register within 7 days of the gift or hospitality being given or accepted. The Benefits Register is located in ................................... [state location]. [See sample benefits register (pdf) (word)]
- You must report any breach of these Rules or any suspicion of corruption as soon as possible to [name and contact details of organisation's relevant reporting line]. If for any reason you do not wish to report to this contact, or if you are not satisfied that your initial report is being properly investigated, you may report to [name and contact details of the organisation's director responsible for implementing the company’s anti-corruption programme].
- In all cases, you may report anonymously. If you do not make your report anonymously, you may request the person to whom you make the report to keep your identity confidential. The organisation will take all reasonable steps to keep your identity confidential unless you give written consent to disclosure of your identity and you have specified the person to whom your identity may be disclosed. However, the organisation cannot guarantee that, if you make a report, your identity will be kept confidential.
If you have published guidance which is relevant to the above recommendations, and if you are willing to provide a link to your website, please send details to GIACC for listing on this page. Only services and tools which are available free of charge will be listed.
Page updated on 5th September 2008
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