Policy and procedures

AC.2.a. Anti-Corruption policy and guidelines

Does the company forbid corrupt behavior and monitor it's anti-corruption initiatives? (Principle 10)

ABOUT THIS QUESTION

Ensuring a culture of anti-corruption involves formulating anti-corruption standards and implementing these in company procedures so that the employees are equipped to handle corruption in compliance with the company's anti-corruption commitment. Communicating pro-active actions to stakeholders and partners is strongly advised in order to prevent corruption demands or requests.

 

The measures taken by the company should be in accordance with national regulatory requirements, international conventions, the precautionary approach and best practice.
Please see for example: ICC guidelines on Whistleblowing; Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations; Business Principles for Countering Bribery. Transparency International; Partnering Against Corruption - Principles for countering Bribery. Partnering Against Corruption Initiative (PACI), World Economic Forum.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company has a policy rejecting corruption and requiring all directors, managers and employees worlwide to behave ethically and in conformity with the law.

The policy includes how to handle requests for facilitation payments, giving and receiving gifts, engaging in sponsorships, giving political contributions, and how to conduct responsible lobbying.

The company has defined benchmarks and indicators regarding its anti-corruption actions and initiatives and reports these to the public (i.e. in its Communication on progress report)

The company publishes its legal cases regarding corruption.

The company has appointed a manager to devise, implement, monitor and improve the anti-corruption initiatives under the oversight of senior leadership.

Step 2. Answer the main question:

Does the company forbid corrupt behavior and monitor it's anti-corruption initiatives?

 

AC.2.b. Anti-corruption procedures

Do the company's internal procedures support it's anti-corruption commitment? (Principle 10)

ABOUT THIS QUESTION

Implementing anti-corruption standards into the core structure of the company relies heavily on the development of suitable procedures which are resistant to corruption and able to raise internal alarms. These alarms are signals regarding occurrences which should be investigated at a higher level in the organization.

 

Please see for example: ICC Tools for Self-Regulation; OECD Risk Awareness Tool for Investors in Weak Governanace Zones; OECD Guidelines for Multinational Enterprises.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company has assigned different individuals or departments to be responsible for handling contracts, placing orders, receiving goods, processing invoices and making payments.

The company mentions "anti-corruption" and/or "ethical behavior" in its contracts with partners in high risk countries, sectors and transactions.

The company prohibits informal employment and any 'off the books' record-keeping

The company performs internal audits and has checks and balances in place in connection with all anti-corruption commitments.

The company's procurement, financial and internal audit personnel have clear procedures on their respective responsibilities to look for and to identify alarms, report them to management, and follow-up counter measures.

The company requests external auditors to maintain a critical eye and follow all alarms and irregularities.

Any alarm or irregularity reported be external auditors is systematically addressed by management.

The company monitors compliance and continuously identifies strengths and weaknesses in the anti-corruption initiatives to remain effective and up-to-date in addressing changing risks.

Step 2. Answer the main question:

Do the company's internal procedures support it's anti-corruption commitment?

 
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    1. Select a question

    2. Click "Answer this question"

    3. Answer the indicators

    4. Answer the main question

     

     

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