Code of Conduct

Anti-corruption provisions for inclusion in a Professional Institution’s Code of Conduct

It is good practice for professional institutions to have a Code of Conduct which provides minimum standards with which its members must comply.

This Code is likely to cover a wide range of issues, such as ethics, corruption prevention, quality, health and safety, environmental protection, discrimination, human rights etc.

The following are recommended Code of Conduct provisions which are specific to corruption prevention.  A professional institution can compare the anti-corruption provisions in its existing Code of Conduct with the following suggested provisions, and can adapt and include the following provisions in its Code of Conduct as appropriate. 

All members of [name of professional institution] must at all times comply with the following principles:

Laws:  You must comply with all laws in all jurisdictions in which you operate.

Criminal activity:  You must not:

  • act dishonestly
  • defraud or deceive anyone
  • give or receive a bribe, or any unlawful payment, benefit or advantage
  • give or receive any gift, hospitality, entertainment, donation, or other benefit that may improperly influence a decision, or impair independence or judgement
  • participate in any unlawful cartel or price fixing arrangement
  • participate in any other criminal activity, such as extortion, abuse of power, embezzlement, or money laundering.

Conflicts of interest:  You must avoid, or deal openly and appropriately with, situations in which your own, or your family’s, personal interests could conflict with your professional obligations or duties.

Ethical behaviour:  You must at all times behave ethically.   Ethical behaviour is a higher standard than the criminal law:  an act may be unethical even if it is not unlawful.  Behaving ethically means behaving in a manner which is truthful, fair, and honest, and which is in keeping with the high standards of your profession.

Professional responsibilities:  You must not knowingly or recklessly:

  • provide, conceal, or approve work, materials, equipment or services which are not of the quality and quantity required under law or contract
  • provide false, inaccurate or misleading information
  • withhold information which another person has the right to see
  • make or submit false, inaccurate, misleading or exaggerated records, invoices, claims, applications for variations or extensions of time, or requests for payment
  • without good reason 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
  • without good reason refuse or fail to pay, or delay in paying, sums due.

Management responsibilities:  Where you have a management responsibility over any function, activity or personnel, you must:

  • not authorise or condone any corrupt activity within such function or activity, or by such personnel
  • take reasonable and proportionate measures to prevent any such corrupt activity from occurring
  • in the event that any such corrupt activity is reported or suspected, take reasonable and appropriate steps to investigate and deal with such corruption.

Direct and indirect actions:  The above obligations apply to any actions taken by you either directly, or through or on behalf of any other person or organisation.

Breach of this Code of Conduct:  In the event that any member breaches any part of this Code of Conduct, then

  • [Name of professional institution] will take reasonable and appropriate steps to investigate such breach.
  • If there is reasonable evidence that such a breach has occurred, then [name of professional institution] will refer the matter to its [Disciplinary Process].

Reporting:  If you suspect that any member of [name of professional institution] has breached any part of this Code of Conduct, then you must report such suspicion as soon as possible to the [name of professional institution] Reporting Line.  The Reporting Line is:

     Name: ………………….

     e-mail: ………….……..

     Telephone: ……………

In all cases, you may report anonymously.  If you do not make your report anonymously, you may at the time of reporting request [name of professional institution] to keep your identity confidential.

Download Word version of above Code of Conduct provisions.

Updated on 15th July 2020