Anti-corruption management system - Components (2)

In relation to the organisation’s personnel:

• Compliance:  Require all personnel to comply with the policy and ACMS (in employment contracts, and/or by compliance declarations).
• Vetting:  Implement appropriate vetting of potential personnel before they are employed to ensure that they will comply with the policy and ACMS.
• Anti-corruption training:  Provide appropriate anti-corruption training to personnel.  Higher risk personnel should receive higher level training.
• Gifts: Implement controls over gifts, hospitality, donations and similar benefits to prevent them from being given or received for corrupt purposes.
• Advice and support:  Provide advice and support to personnel who are faced with corruption issues in their employment.

In relation to the organisation’s activities:

• Risk assessment:  Undertake appropriate corruption risk assessments and due diligence on transactions and business associates (i.e. clients, joint venture partners, contractors, suppliers and consultants) to ensure that the organisation’s corruption risks are identified and are adequately dealt with, and that the organisation only works with ethical business associates.
• Controls:  Implement appropriate financial, procurement, commercial, sales, and project management controls over the organisation’s transactions so as to reduce corruption risk (e.g. separation of functions, two signatures on payment / work approvals).
• Business associates: Take reasonable steps to ensure that business associates which pose more than a low corruption risk:
  • have themselves implemented appropriate anti-corruption controls
  • provide appropriate anti-corruption commitments.

Reporting corruption:  Implement procedures by which suspected corruption or breach of the policy or ACMS involving the organisation or its personnel can be reported to the organisation by any personnel, business associates or members of the public.  Anonymous and confidential reporting should be permitted.

Investigating and sanctioning corruption:  Investigate and deal appropriately with any suspected or actual corruption or breach of the policy or ACMS.

Monitoring and auditing the system:  Monitor and audit the effectiveness of the ACMS and improve it as necessary.