How to prove that an organization implements anti bribery policy



Any thoughts about how to prove that an organization implements anti bribery policy?

IATF-16949 requires organizations to define and 'implement' anti bribery policy. It is easy to make policies, but how to prove that we implement those policies?


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My company has an Integrity Award given annually to an employee who has gone above and beyond to demonstrate the company's culture of ethics. Approximately 50% of the time it has been awarded to someone that turned down a major sales opportunity because it required payment of a bribe. The award gets heavy internal press, videos and mention in employee meetings.

See the Ethisphere award and criteria for some more ideas.


Super Moderator
Until the human element is removed no anti-bribery policy or any other policy will be won't happen


If you have the policy sorted then its a matter of demonstrating that it has been communicated to the staff and a sign off system is required

So you should conduct anti-corruption compliance and awareness training

Anti-corruption training is a necessity and especially true for global organizations entering or active in countries with a history of corruption.

At a minimum, all employees and agents in a position to give or receive bribes, or to detect such activity, should receive anti-corruption compliance training

The training should highlight:-

• Corporate anti-corruption policies and procedures
• Details of how employees can get further guidance on matters
that they are unsure about
• Potential “red flags” or problem situations
• How to report and escalate potential violations
• That corruption will not be tolerated

You should consider a mixture of live training for some higher-risk employees and web-based training for all employees.

Senior management, employees in sales, marketing, finance, legal, M&A and internal audit should receive enhanced training, customized to their
particular roles.

The training program should be regularly updated and provided to new
or transitioning employees.

It should include a test, which must be passed, to demonstrate
that employees understand the concepts and practical implications of the material

Many companies complement their training programs with a certification program, whereby the employee certifies that he or she has taken the training, understands his or her responsibility and has reported any and all incidents of corruption that they are aware of

The sign off or certification is evidence that you have a implemented an anti-corruption policy and is understood by the staff

Demonstrating Effectiveness

The design, implementation and monitoring of an anti-corruption compliance program must be accurately documented

This documentation provides vital evidence of the organization’s commitment to meeting its requirements under applicable statutes.

In the event that potential bribery is identified, anti-corruption compliance documentation will help to demonstrate that the bribery was performed in violation of the company’s policies

The documentation may also show that the perpetrator knew or should have known that hey were in breach of company policy

In my experience, the effectiveness of anti-corruption compliance program is dependent on a clear requirement for consistency and a rigorous approach to documentation

Implementing a program that is not consistent or rigorous creates a greater risk for the business.



Involved In Discussions
Anti-bribery is one that I am also looking at.
As Randy said, when people are involved the system cannot be foolproof, however in the UK legislation this has been recognized, as demonstration of a system, with effective training and monitoring can be used as a legal defence.

All of the points made by SKPEvans are the same as we have taken, combined with guidelines on what levels of hospitality or gifts can be allowed, with an approval process for spend. The limits are set pretty tight (it wouldnt meet the cost of taking a client out for lunch in London without having to obtain authorization).

One useful additional step that we have put in place is to monitor expense claims. Where the value and detail are higher than the allowable levels, the Accounts Team check for spend levels and reasons and are able to verify against authorisations provided.

This works well and underpins the training and culture that we are creating to minimize our risks.

Hope this helps.


We have a Anti Bribery and Corruption policy in place and a documented procedure. We then have all employees acknowledge it by signing a statement like this: I the employee hereby confirm that i have read an understood the abc policy ... and so on "
on our yearly staff appraisal forms.

Definately not sufficient in my mind though, but a start :)


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Any thoughts about how to prove that an organization implements anti bribery policy?

IATF-16949 requires organizations to define and 'implement' anti bribery policy. It is easy to make policies, but how to prove that we implement those policies?

I think it depends on your organization. If your a large multinational corp., a complicated multilevel training and verification system may work. But for a smaller tier 3 component supplier, maybe a simple signed acknowledgement would work. And then everything in between. Good luck.


Thanks for all replies. And SKpevans, your explanation really help me to understand this new requirement.
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