Anti-corruption management system - Components (1)

The following two pages summarise the key components of an effective anti-corruption management system.

Top management:  Ensure that the organisation’s top management:

• provides leadership in ensuring that corruption is prohibited throughout the organisation
• has overall responsibility for implementing and ensuring compliance with the anti-corruption policy and anti-corruption management system (ACMS).

Policy:  Establish an anti-corruption policy (sometimes called a code of conduct) which:

• prohibits any involvement by the organisation and its personnel in corruption
• requires personnel to prevent and report corruption or breach of the policy or ACMS where it is safe to do so.

Compliance function:  Appoint a person(s) to oversee compliance by the organisation and its personnel with the policy and ACMS. 

Delegated responsibility:  Allocate responsibilities for ensuring compliance with the policy and ACMS throughout the organisation.  e.g.:

• department heads are responsible for compliance in their department
• all personnel are responsible for their personal compliance.

Decision making: Ensure that appropriate controls are in place over the making of decisions in relation to transactions which have more than a low corruption risk (e.g. appropriate seniority of decision maker, no conflicts of interest).