Overview of an Anti-corruption Policy

An anti-corruption policy states the code of conduct which an organisation operates on. Importantly, it marks out the measures a business has taken to minimise the risk of corruption in a transparent and honest manner.  

What is an anti-corruption policy?

Unfortunately, corruption can take place in many forms and endangers the reputation and growth of any organisation. Thus, it’s important for businesses to have their own anti-corruption policy to help establish the corporate culture of a business. Additionally, to spell out the consequences of all kinds of corruption. In essence, corruption is dishonest or fraudulent conduct by those in power, typically involving bribery.

Preventative and reactive measures within your anti-corruption policy.

Essentially, there are two methods for establishing an anti-corruption policy which are wise to adopt in tandem —preventive and reactive. Firstly, preventive measures focus on minimising corruption through the adoption of clear rules and regulations within a business. Secondly, reactive measures are the consequences should anyone bend or break these rules. Typically, this includes punishments, penalties or zero tolerance. Importantly, an anti-corruption policy should circulate through all staff members on every level as well as directors and members of the management board. Additionally, it’s imperative to have employees both understand and acknowledge the requirements of the policy.  

What is bribery?

In a nutshell, bribery is the unethical or illegal activity that involves the exchange of something of high value. Often, this includes money, expensive gifts, and scholarships & donations with the purpose of influencing the behaviour of employees inside an organisation. Notably, a corrupt act has occurred even if a bribe is not accepted. 

What should be in an anti-bribery & anti-corruption policy?

  • Pledge to adopt ethical and anti-corruption business practices;
  • Scope of the policy;
  • Statement of policy against corruption in doing business and zero tolerance of corruption of any form;
  • Key integrity and conduct requirements for the company’s personnel;
  • Ethical and anti-corruption requirements for business partners;
  • Whistle-blowing policy for corruption and violation of the anti-corruption policy, and policy on the handling of reports; and
  • Brief description of the company’s anti-corruption programme.
  • A clear distinction between what is and isn’t acceptable in relation to gifts. 

Establishing an anti-corruption programme

 Essentially, an effective anti-corruption programme should include the following elements:

  • An Anti-Corruption Policy;
  • Ethical standard and anti-corruption guidance for all company personnel, including directors and staff, through a Code of Conduct;
  • A mechanism for the identification and assessment of corruption risk;
  • Anti-corruption control;
  • Training and communication.

Additionally, apart from putting in place an Anti-Corruption Policy, it is important that this policy is properly communicated to all your stakeholders. After all, company policies and business processes are carried out by people. Importantly, business owners need to take steps to promote an ethical, anti-corruption and compliance friendly culture within their company. Essentially, this will help build capacity for corruption prevention among staff at all levels. Notably, one of the best ways to increase awareness is by organising workshops and training. Also, clearly communicating to whom an employee should take their suspicion or anti-corruption complain to. Typically, this will be the HR department in larger companies. 


To conclude, the anti-corruption policy should be a part of every corporate HR toolkit. Again, a clear and transparent guide to employees will help to protect your business against acts of corruption.

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