This section provides guidance in relation to an organisation communicating the anti-corruption policy and programme (Measure 4 of the Anti-Corruption Programme for Organisations).
The purpose of this measure is to ensure that all personnel are aware of the anti-corruption policy and programme, and are aware that the organisation’s top management is committed to the policy and programme and requires personnel to comply. The policy and programme will not be effective if personnel are unaware of them, or do not believe that they are fully supported by the top management.
There are three components to this measure:
All of the statement of support, anti-corruption policy and personnel confirmations should be dated so that it is clear when they were published or agreed to.
It is important that the organisation can efficiently keep track of those personnel who have received the anti-corruption policy, those who have signed the compliance declaration, and those who have not (so that the organisation can follow up in relation to those personnel who have not received the policy or who have not signed the declaration). There are various ways in which the organisation can manage and monitor these arrangements:
The anti-corruption programme requirements which support the policy are likely to be contained in a wide range of documentation and controls (see Measures 3 to 21). These may change periodically as they are updated and improved. Not all programme requirements will be relevant to all personnel (for example, project management controls may only be relevant to project managers). It would be likely to be too cumbersome to require all programme requirements to be sent out to all personnel and to be signed by personnel in the same way as the policy above. So, an effective method of communication of the relevant programme requirements must be implemented so that all personnel are aware of the programme requirements relevant to them. Appropriate training or instruction should be given to relevant personnel so that they are aware of how to implement the programme requirements relevant to them.
Updated on 10th April 2020