Anti-Corruption Tools

Reporting corruption

As explained in What is corruption, GIACC uses the term "corruption" in the wider sense to include bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement, trading in influence and money laundering. Consequently, the discussion in this section applies to all such criminal activity.

A proper reporting system is necessary to enable an organisation to prevent and detect corruption. It will also provide officers and employees with some assurance that the organisation intends to implement its anti-corruption policy properly. The system may be an internal system, or it may be contracted out to a specialist reporting company. This reporting system should form part of the organisation’s Anti-Corruption Programme.

In this section, "employee" refers to officers and employees of an organisation.

Features of a corruption-reporting system

The reporting facility should be available and easily accessible to all employees.
All employees should be informed about the system and how it operates.
Employees should be required to report to the employer as soon as reasonably possible any suspected or actual corruption, or any activity which could facilitate corruption, unless they have reasonable grounds to believe that such reporting would endanger their own or another person’s personal safety.
Confidential reporting should be permitted.
Anonymous reporting should be permitted.
The organisation should use all reasonable endeavours to keep reports confidential.
The organisation should use all reasonable endeavours to keep the identity of the reporting individual confidential.
The organisation should disclose the identity of the individual only if the individual agrees that it may be disclosed and agrees to whom it may be disclosed.
A senior officer should be appointed as responsible for receiving, reviewing and promptly referring reports to the appropriate director.
A director should be appointed to take ultimate responsibility for investigating and dealing with any report, and ensuring that the individual who made the report is properly protected and does not suffer any adverse discrimination.
Each report should be recorded in writing by the organisation and kept for as long as may be necessary to support any criminal proceedings.
Each report should be properly investigated by the organisation.
The individual who made the original report should be kept informed of the action being taken to the extent that this information does not prejudice any investigation or endanger the safety of the employee or any other person.
There should be a facility for an individual to make a further report to a more senior officer if he feels that his initial report is not being properly dealt with.
The organisation should not permit any adverse discrimination against any individual who has made a report in good faith.
The organisation should take all reasonable steps to protect the safety of any individual who has made a report in good faith.
Employees should be assured that they will not suffer any adverse discrimination as a result of making reports in good faith and that the organisation will take all reasonable steps to protect their identity and safety.
With regard to reporting by the organisation to the criminal authorities, see Dealing with corruption: Organisations.
The organisation's anti-corruption rules and employment terms for its employees should include appropriate terms to ensure that the above reporting system can be implemented.

Additional reporting provisions for funders and project owners in relation to projects

In addition to the internal reporting mechanisms referred to above, a funder and project owner should each implement a reporting mechanism on projects in which they are involved as follows:

They should publicly disclose that they are the funder or project owner for a particular project and state that any project participant or member of the public may report matters of suspected or actual corruption in a confidential manner to their appropriate senior manager.
The name and contact details of the manager to whom reports may be made, and the reporting procedures, should be published on their respective web-sites, and (if there is one) on the project web-site.
The same protections and facilities should be provided to persons who make reports as are recommended above for employees.
With regard to reporting by the organisation to the criminal authorities, see Dealing with corruption: Organisations.

Other Resources

Some organisations have published information on reporting. This information is listed below in alphabetical order according to the name of the organisation which has published it. If the following details are inaccurate or incomplete, or you wish details of a reporting resource which is not listed below to be listed, please send details to GIACC. Only resources which are available free of charge will be listed.

BSI British Standards has published “PAS 1998 Whistle-blowing Arrangements Code of Practice”. This Publicly Available Specification (PAS) sets out good practice for the introduction, revision, operation and review of effective whistle blowing arrangements

International Chamber of Commerce (ICC) has published “Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations” which provides as follows:

“Article 7: Corporate Policies

In order to prevent bribery and extortion, enterprises should implement comprehensive policies or codes reflecting these Rules of Conduct as well as their particular circumstances and specific business environment. These policies or codes should:

a) …..

b) offer confidential channels to raise concerns, seek advice or report violations without having to fear retaliation;

ICC has published a global standard on the creation of whistle-blowing programmes. The guidelines take into account the different cultural and legal environments that have inhibited a universal standard in the past.

TI’s “Business Principles for Countering Bribery” contains the following recommendations

6.5 RAISING CONCERNS AND SEEKING GUIDANCE

6.5.1 To be effective, the Programme should rely on employees and others to raise concerns and violations as early as possible. To this end, the enterprise should provide secure and accessible channels through which employees and others should feel able to raise concerns and report violations (“whistleblowing”) in confidence and without risk of reprisal.

6.5.2 These channels should also be available for employees and others to seek advice or suggest improvements to the Programme. To support this process, the enterprise should provide guidance to employees and others with respect to the interpretation of the Programme in individual cases.

TI’s “Guidance Document” to the Business Principles" (pages 50-54) contains advice and commentary on whistle-blowing.

TRACE operates BRIBEline which provides a secure and anonymous facility to report requests for bribes. BRIBEline's purpose is to collect information about the official or quasi-official entities – governments, international organisations, security forces, state-owned enterprises, etc. – around the world that solicit bribes. BRIBEline focuses on demand-side bribery only. It does not request or collect information about those who pay, or offer to pay, bribes, or collect or request any names. The information it collects will not be used to take legal or investigative action. Aggregate information will be made public to shine a spotlight on trouble spots so that they might be improved, and to allow companies to manage risk better.

UK Anti-Corruption Forum’s “Anti-Corruption Action Statement” provides as follows:

“7. Actions for companies working in the sector

Companies working in the sector can play a major role in eliminating corruption. The Forum recommends that companies take the following steps.

a)        …..

b)        Companies should maintain an anti-corruption policy which:

i)         …..

iv)       provides for effective anti-corruption management controls, audit, staff training, and whistle-blowing procedures.”

World Economic Forum Partnering against Corruption Initiative (PACI) has published “Partnering against Corruption Principles for Countering Bribery” which provides as follows:

“5.5 Raising Concerns and Seeking Guidance

5.5.1       The Programme should encourage employees and others to raise concerns and report suspicious circumstances to responsible enterprise officials as early as possible.

5.5.2       To this end, the enterprise should provide secure and accessible channels through which employees and others can raise concerns and report suspicious circumstances (“whistle blowing”) in confidence and without risk of reprisal.

5.5.3       These channels should also be available for employees and others to seek advice or suggest improvements to the Programme. As part of this process, the enterprise should provide guidance to employees and others on applying the Programme’s rules and requirements to individual cases.”

Page updated on 5th September 2008.

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