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 anti-corruption policy and programme, and all procedures and controls which form part of the programme.
  • The steps taken to implement the anti-corruption programme.
  • Documents which record the implementation of the programme, such as:
    • board resolutions
    • communications to personnel informing them of the anti-corruption policy and programme and the importance of compliance
    • appointment and scope of work of compliance manager
    • personnel vetting and appointment
    • disciplinary procedures
    • personnel bonus procedures
    • receipt by personnel of anti-corruption policy
    • training provided
    • conflict of interest register
    • register of gifts, hospitality, political and charitable donations and other relevant benefits given and received
    • levels of delegation of authority
    • risk assessments and due diligence carried out
    • steps taken to assess anti-corruption controls of relevant business associates
    • anti-corruption contract clauses
    • financial controls
    • commercial controls
    • compliance manager reports
    • internal audit reports
    • reports received from personnel or other third parties of actual or suspected corruption
    • incidents of suspected or actual corruption
    • investigations carried out
    • enforcement actions
    • steps taken to review and improve the anti-corruption procedures
    • any other records relevant to the anti-corruption programme.

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.

Implementation checklist for Measure 20

  1. The organisation should assess what records they need to retain and for how long.
  2. The organisation should assess which department or function is most suitable for retaining which type of records.
  3. The organisation should ensure that these records are prepared and retained, and are easily accessible by relevant personnel.

Updated on 10th April 2020