Procedure to Prevent Corruption

Question I have in an assessment form from a potential supplier :

" Does your operation have policies and procedures in place to prevent and detect corruption by your employees, officers, managers, and any other working behalf of your operation, including but not limited to bribery, excessive gift-giving, extortion, or embezzlement, on the part of suppliers, contractors or agents representing the facility? If yes, please use the comment field below to describe those policies and procedures.
"

Can someone help ? I've nothing in our set of internal procedures ...

Thanks to all in advance !

LesPiles

We don't have this in our procedures, they are in the employee handbook. I don't know if a procedure would be a correct place for this type of thing (unless it is the procedure to investigate).

As a note, I am located in the USA and that might may make a difference.

LesPiles,

Usually anti-corruption policies are issued from the top. Quite often as an annual memo or email from the CEO.

Here is an example: https://www.rb.com/documentdownload.axd?documentresourceid=9902

Such policies may spawn new procedures or tweaks to existing sales procedures.

Or you could develop your management system to meet the requirements of BS 10500.

John

these are typically issued form legal or HR - not the QA group.

'prevention' is tough of course but typically an annual memo, refresher training (my organization uses an online training with a 'test' that provides objective evidence that each employee was trained adn retained that knowledge at least long enough to pass the test), etc.
some acceptable actions are:

• policies about who can approve expense reports, fro example fi a group of people are having a working meal or other event the ranking approving member must submit the expense report so that the approver was not also in attendance.
• policies regarding the financial limit for expenses requiring receipts
• objective evidence that approvers looked at the receipts
• rotation of financial persons and supplier contacts including buyers to minimize the exposure to bribery or stealing
• policies against hiring 'relatives' as contractors or service providers
• policies that prohibit married, dating or fraternizing couples form working in an org structure where one is the manager of the other; or one is in HR, or legal

You get the drift...

detection is easier. typically this involves audits - of financial records, expense reports, inventory counts, etc. and the use of cameras to detect physical theft or time card forgery.

hope this gives you some ideas.

I've also seen ethical policies in place and procedures regarding gifts from clients.

LesPiles said:

Question I have in an assessment form from a potential supplier :

" Does your operation have policies and procedures in place to prevent and detect corruption by your employees, officers, managers, and any other working behalf of your operation, including but not limited to bribery, excessive gift-giving, extortion, or embezzlement, on the part of suppliers, contractors or agents representing the facility? If yes, please use the comment field below to describe those policies and procedures.
"LesPiles

Click to expand...

I'm in the middle of writing a policy on this sort of thing now. Policies and procedures are just words. Its management applying, with rigor, all the requirements of clause 8.2.3 Monitoring and measurement of processes of ISO 9001 that is going to make the words on paper have any meaning.

LesPiles said:

Question I have in an assessment form from a potential supplier

Click to expand...

Supplier or Customer?

Many large organizations have Codes of Conduct where they establish how they set policies and manage the ethics and integrity in their operations. Some countries have strict anti-corruption laws and there is a growing level of scrutiny on organizational ethics and compliance. Because of that, some standards have and are being developed, such as the one mentioned by John Broomfield.

John Broomfield said:

Or you could develop your management system to meet the requirements of BS 10500.

Click to expand...

ISO is already working on their own version of the standard: ISO/NP 37001 Anti-bribery management systems and there are anti-corruption certification programs in place already, such as the one available at http://www.ethic-intelligence.com/certification/

Most organizations define these things in the Code of Business Ethics and each employee sign it after joining the organization.

With a key word "ombudsman policy and procedures" search in google and from there pick your inputs to make a procedure suitable for your organization ...

We've had one of those questionnaires from a customer before. Not sure if right thing but it got answered honestly and we told them we don't have a policy. Small company getting asked big company questions IMHO.

Not denigrating ethics and anti-corruption policies and the passing of it down to suppliers. It is very important, but a small company is usually based on a small number of people in contact with customers and suppliers directly. Perhaps even down to the boss, an assistant and someone who wear the purchasing, operations, quality, etc. hat. Trusted employees who quite possibly grew up with the company. Whilst there is no policy written down the integrity of the owner/boss dictates whether a corrupt person can exist in the organization.

I appreciate these questionnaires are done with good purpose but sometimes I wonder if it is a task given out so some system gets a tick on its "required actions". So I fill them in honestly and have never had anyone come back insisting on getting a policy or procedure written for preventing, detecting or responding to corruption. This is not the case with quality, environmental and occupational health and safety. We have had customers come back about them. Is that something to do with big companies not giving this matter as much priority? Are they just ticking a box on their corporate responsibility check list without a threat of any authority getting on their case? Of course some countries no doubt have anti-corruption legislation and some even enforce it (perhaps against other nations' companies only). Sorry am I a cynical individual?