Anti-Corruption Tools
Anti-Corruption Code
As part of its anti-corruption programme, an organisation should adopt an anti-corruption code. (See index on left of page for various Anti-Corruption Programmes.)
An anti-corruption code should:
- Address the issue of corruption directly and expressly. Reference to a requirement to act with integrity is not adequate.
- Publicise the business and moral case against corruption.
- Prohibit its officers and employees, and those of its branch offices and those related companies which it controls, from engaging in any form of corruption in relation to the organisation's business and affairs.
- Commit the organisation to use all reasonable endeavours to conduct its business and affairs so as to ensure that it does not engage in or facilitate any form of corruption.
- Specify clearly the organisation’s gifts policy on donations, gifts and hospitality.
- Specify the organisation’s policy on facilitation payments. These are small payments which are in some countries frequently extorted by government officials in return for the performance of their duties. Making such payments may be a criminal offence. The aim of the organisation should be a ban of these payments save in cases where the well-being of any person is endangered.
- Support anti-corruption action by others in the sector.
- Provide a reference to the specific steps being taken by the organisation to combat corruption both internally and in dealings with third parties.
Sample Anti-Corruption Code
- For the purposes of this Code, "corruption" includes bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement, trading in influence, money-laundering and similar criminal activity.
- Corruption causes poverty and suffering, inhibits economic growth, is damaging to business, and may result in criminal and civil liability and penalties for organisations and individuals.
- [Name of organisation] prohibits its officers and employees, and those of its branch offices and those related companies which it controls, from engaging in any form of corruption in relation to [Name of organisation]'s business and affairs.
- [Name of organisation] will use all reasonable endeavours to conduct its business and affairs so as to ensure that it does not engage in or facilitate any form of corruption.
- In order to minimise opportunity for corruption, [Name of organisation] does not make any political or charitable donations, or provide gifts or hospitality to any person or organisation. It also prohibits the receipt by [Name of organisation] or any of its officers or employees of any donations, gifts or hospitality.
- [OR, as an alternative to paragraph 5] In order to minimise the opportunity for corruption, [Name of organisation] does not make any political or charitable donation, or provide any gift or hospitality to any person or organisation which are in excess of [$ .....]. It also prohibits the receipt by [Name of organisation] or any or its officers or employees of any donation, gift or hospitality which is in excess of [$ .......]. All donations, gifts and hospitality provided or received by [Name of organisation] or its officers or employees must be recorded in a gifts register which is routinely inspected.
- A facilitation payment is a payment made to encourage a person to carry out his duty. Even though facilitation payments are in many cases obtained by way of extortion, they are nevertheless a form of corruption and the making or receiving of a facilitation payment is a criminal offence in many jurisdictions. [Name of organisation] prohibits the making of any facilitation payment, save in circumstances where the personal safety of any person is endangered.
- Anti-corruption action by individual organisations is not sufficient to reduce corruption in the [infrastructure] sector to any significant extent. There must, in addition, be concerted and collaborative action by all stakeholders. [Name of organisation] supports international efforts and works with other stakeholders to reduce corruption in the [infrastructure] sector. [Details of these collaborative efforts which [Name of organisation] supports can be found at [web reference]].
- [Name of organisation] has adopted a corporate anti-corruption programme
to enable it to comply with this Code. [Name of organisation] will
properly implement this programme and review it on an annual basis
to ensure that it is operating effectively. This programme can be
found at [web reference].
Other Resources
If you have published guidance which is relevant to the above recommendations, and if you are willing to provide a link to your website, please send details to GIACC for listing on this page. Only services and tools which are available free of charge will be listed.
Page updated on 1st May 2008
© 2008 GIACC