Decision-Making Process

This section provides guidance in relation to the requirement that an organisation should implement a procedure which ensures that the decision-making process and the seniority of the decision-maker are appropriate for the value of the transaction and the perceived risk of corruption (Measure 13 of the Anti-Corruption Programme for Organisations).

In very small organisations, the top one or two managers will normally take all decisions, and there will be no delegation of authority.  However, in larger organisations, due to the number of personnel and functions in the organisation, it will be necessary for the board to delegate decisions to one or more board members and/or to managers below board level.

Most larger organisations will have a written approval matrix which states which decisions can be made by a particular manager(s) according to the financial size of the transaction.  Larger value items will normally require at least two manager approvals, and the seniority of the approver will normally increase according to the size or risk of the transaction.  High value transactions may require board approval.

The organisation should introduce corruption risk as an additional factor in this decision making process.  While corruption risk can increase in accordance with the financial value of a transaction, this is not necessarily the only factor.  A low value transaction may carry a high corruption risk (e.g. obtaining a work permit).

The organisation should, therefore, as part of its risk assessment (see Organisation Corruption Risk Assessment), assess the type of transaction which carries a corruption risk, and the likelihood and extent of this risk.  A transaction which carries a more than low corruption risk should need the approval of at least two managers, and their seniority should be appropriate to the level and likely impact of the risk.  High corruption risk transactions which could have a significant adverse impact on the organisation are likely to require board approval.

It is possible that a low value but high corruption risk transaction will need the same senior level of approval as a high value transaction in the organisation’s approval process.

See attached sample of an Approval Matrix.

Implementation checklist for Measure 13

  1. The organisation should identify from its Organisation Corruption Risk Assessment which types of transaction carry more than a low corruption risk.
  2. The organisation should agree at board level and publish a written approval matrix (see sample matrix) which ensures that transactions which carry more than a low corruption risk require the approval of at least two managers, and that the number of approvals and seniority of the managers approving are appropriate to the level and likely impact of the corruption risk.

Updated on 10th April 2020