This section provides guidance in relation to the requirement that an organisation should keep reasonably detailed records of its anti-corruption policy and programme and any compliance issues which arise (Measure 20 of the Anti-Corruption Programme for Organisations).
These records should include the following:
The extent of documented information can differ significantly from one organisation to another according to the size of the organisation, the extent of the corruption risk it faces, and the complexly of the organisation’s structure and operations.
Documented information can be retained separately as part of the anti-corruption programme, or can be maintained as part of other management systems (e.g. compliance, financial, commercial, human resources, audit etc.). The key point is that relevant documentation must be retained, and must be easily accessible by relevant personnel.
Records may be kept in hard copy and/or electronically.
Part of the necessity for this record keeping requirement is that the preparation and retention of good records is a normal part of good corporate management. However, in addition, if the organisation or its personnel ever get investigated for corruption, these records will form a vital part of the organisation’s and personnel’s defence by helping to demonstrate that they had taken adequate steps to prevent corruption. As a corruption investigation can take place many years after the occurrence of the event, it is highly likely that personnel may have left the organisation or that memories will have faded. Therefore, good records are vital.
Updated on 10th April 2020