This anti-corruption programme is designed to be used by all organisations, including:
It is applicable to small, medium and large organisations in the public, private and voluntary sectors.
Organisations face serious risk of incurring criminal and civil liability, financial loss and reputational damage due to corruption by their personnel and business associates. To minimise this risk, organisations should implement a management programme to prevent, detect and deal with corruption both within their own organisation and in their dealings with their business associates.
An anti-corruption programme will not guarantee that there will be no corruption. However, it could materially assist in its prevention and detection. In addition, in the event of possible prosecution of the organisation or its personnel, such a programme could provide important evidence that the organisation had taken reasonable steps to prevent corruption. This may help to avoid or mitigate criminal liability.
GIACC provides below an anti-corruption programme (which includes programme measures, guidance and templates), which can help an organisation implement or improve its anti-corruption programme. As all GIACC tools are prepared specifically for the infrastructure sector, this programme has been designed with this sector in mind. However, the programme can be used by organisations in all sectors.
This GIACC programme incorporates international good practice, and so can be used in any country. It is consistent with the international standard ISO 37001 Anti-bribery Management System. It comprises policies and procedures which an organisation can integrate into its management procedures so as to help it reduce the risk of corruption.
The intention of this programme is to reduce the risk of corruption:
The anti-corruption programme should be implemented by the organisation with care and attention at least equal to that given to any other corporate management or audit process (e.g. safety or quality). The measures recommended in this programme should be adapted by the organisation to take account of the organisation’s specific requirements, and should be implemented in a manner which is reasonable and proportionate to the corruption risk which the organisation faces. In particular, the programme should be modified according to applicable laws, the size of the organisation, value and nature of business transactions, location of projects, and perception of risk. Low value or low risk contracts or projects are likely to require a lower level of preventive action than high value or high risk contracts or projects. However, it should be remembered that while commercial risk may be lower in relation to lower value contracts or projects, the criminal risk may remain the same. There is no precise recipe for such modification. This is a value judgment to be made by the organisation itself. Guidance is given in the links below to assist in such judgement.
An organisation can copy and use the GIACC programme below at no charge. However, no organisation is permitted to sell the whole or part of GIACC’s programme.
GIACC is providing the following anti-corruption programme (which includes programme measures, guidance and templates) at no cost in order to help prevent corruption. GIACC does not guarantee that the programme will in practice stop all corruption or prevent or mitigate criminal liability, and GIACC is not liable to any organisation or person who uses the programme.
The following paragraphs list a series of measures which constitute the anti-corruption programme.
Guidance on implementation of the measures is contained on separate web-pages. Click on the measure title to access the relevant guidance. In some cases, templates have been provided in order to assist in implementation. These can be accessed from the relevant guidance page.
The following definitions apply to this programme:
The organisation should implement the following anti-corruption measures.
Several organisations have published resources which assist in the implementation of anti-corruption measures. These organisations and their resources are listed below in alphabetical order. If the following details are inaccurate or incomplete, or if there are other recognised international resources to be added, please send details to GIACC.
APEC has published the Hanoi Principles for Voluntary Codes of Business Ethics in the Construction and Engineering Sector.
British Standard BS 10500: Specification for an anti-bribery management system. This is a management systems standard, together with attached guidance, published by British Standards. It can be independently certified in a similar manner to ISO 9001, ISO 14001 and ISO 45001. See GIACC summary on BS 10500. BS 10500 was superseded in October 2016 by ISO 37001 but is still being used by some organisations. See GIACC summary on ISO 37001.
Business Anti-Corruption Portal has produced the following anti-corruption resources and tools:
Centre of Anti-Corruption Studies provides resources for the study and analysis of issues pertaining to the fight against corruption in Hong Kong and internationally. It is a research institute established in 2009 under the auspices of the Hong Kong Independent Commission Against Corruption.
FIDIC – International Federation of Consulting Engineers has published its Integrity Management System (FIMS), which is designed to help businesses deal with integrity risks.
Global Transport Knowledge Partnership (GTKP) is developing a data base of reports and actions in relation to good governance and corruption prevention on road projects.
International Chamber of Commerce (ICC) has published Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations (2005).
International Organisation for Standardization (ISO) ISO 37001 anti-bribery management systems standard. This is a management systems standard, together with attached guidance, which was published in October 2016. It can be independently certified in a similar manner to ISO 9001, ISO 14001 and ISO 45001. See GIACC summary on ISO 37001.
Organisation for Economic Co-operation and Development (OECD) has produced the following resources:
Transparency International has produced, in conjunction with several leading international organisations, the Business Principles for Countering Bribery suite of documents designed to assist organisations to implement and manage an effective anti-bribery system.
World Economic Forum – Partnering against Corruption Initiative (PACI) has adopted the PACI Principles for Countering Bribery which are closely modeled on TI’s “Business Principles for Countering Bribery”.
World Federation of Engineering Organisations (WFEO) has published an Anti-Corruption Action Statement recommending anti-corruption actions for professional engineers, professional engineering institutions, governments, project owners, project funders, and companies. This has been published in two language versions:
Updated on 10th April 2020