SAMPLE ANTI-CORRUPTION CODE OF CONDUCT FOR PROFESSIONAL INSTITUTIONS

All members and employees of [name of institution] must at all times comply with the following principles when carrying out their professional or employment functions:

You must:

• behave in a manner which is truthful, honest, and fair, and which is in keeping with the high standards of your profession and employment
• comply with all applicable anti-corruption laws and standards.

You must not participate in any corrupt activity.  In particular:

• you must not:
  • defraud or deceive anyone
  • offer, give, request or accept a bribe, or any other unlawful payment, benefit or advantage
  • participate in any unlawful cartel or price fixing arrangement
  • abuse the powers or responsibilities with which you have been entrusted
  • misuse funds with which you have been entrusted
  • participate in any money laundering activity
  • facilitate any of the above actions.
• 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, or where such withholding could mislead another person
  • 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.

You must not participate in any activity which could constitute, or be seen to constitute, an improper influence or conflict of interest.  In particular, you must not:

• offer, give, request or accept any gift, hospitality, entertainment, donation, or other benefit that may improperly influence a decision or impair independence or judgement
• participate in situations in which your own, or your family’s or close friends’, personal interests could conflict with your professional or employment functions or responsibilities (unless the conflict is fully disclosed to, and your continued participation is approved by, all relevant parties).

In carrying out your management responsibilities:  Where you have a management responsibility in your profession or employment over any function, activity or personnel, you must, in relation to such function, activity or personnel:

• not authorise or condone any activity which is prohibited by this Code of Conduct
• take reasonable and proportionate measures to prevent any such activity from occurring
• in the event that any such activity is reported or suspected, take reasonable and appropriate steps to investigate and deal with such activity.

Direct and indirect actions: 

The above principles apply to any actions taken by you either directly or through or on behalf of any other person or organisation.

Reporting of breach of this Code of Conduct:  

• If you suspect that any member or employee of [name of institution] has breached or is about to breach any part of this Code of Conduct, then you must report such suspicion as soon as reasonably possible to [name of institution] in accordance with its reporting procedure (which can be accessed at [website link]).
• The above obligation to report does not apply if you fear for your safety, or the safety of another person, if you make such a report.
• 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 institution] to keep your identity confidential.
• In the event that [name of institution] receives a report, or identifies that any of its members or employees has breached or is about to breach any part of this Code of Conduct, then [name of institution] will investigate and apply appropriate sanctions in accordance with its investigation and disciplinary procedures (which can be accessed at [website link]).