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.
So, this is what our anti corruption draft document says
Anti Bribery and Corruption policy
xyz is a private company who helps its clients extend the life of its infrastructure assets in various places in the world. A reference to xyz in this policy includes its related entities.
The directors are committed to responsible corporate governance and ensuring that only legitimate, legal, professional and ethical business practices are employed when doing business with its target market .
This Anti Bribery and Corruption policy is endorsed by the directors of xyz.
The purpose of this policy is to:
1. Define the company?s position on bribery and other forms of corrupt behaviours.
2. Define the responsibilities of company directors, it?s officers, employees, consultants and contactors, otherwise referred to as ?Our People? for the purposes of this policy and its subsidiary documentation.
3. Promote compliance with Anti Bribery and Corruption laws in countries in which xyz operates.
Legislative foundation
The legislative basis of this policy are the anti corruption laws of Australia namely, the Commonwealth Criminal Code and Corporations Act 2001 (Australia) and its equivalent legislation in the countries in which xyz operates. Where there is no such laws exist, the requirements of the United Nationals Anti-Corruption Convention and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, applies.
Prohibited Actions
Corrupt payments ? Our People must not make, offer to make, promise to make or authorise any improper payments or anything of value to public officials, political candidates, political parties or party officials, private individuals or private sector officers or employees, to influence or reward any action by that party.
Indirect payments - These prohibitions also apply to any payments or provision of anything of value by a third party for or on behalf of the company. xyz employees must not make, offer to make, or authorise payment to a third party (e.g., sales agent, distributor or intermediary) with ?knowledge? that all or part of the payment will be offered or given to any individual to secure an improper advantage, or obtain or retain business.
Public and private sectors - These prohibitions apply to existing or potential business arrangements to dealings both in the public or private sectors.
Government officials - These prohibitions apply to payments made to or at the request of government officials, which are of particular concern due to the existence of specific anti-corruption laws in the countries in which we operate.
Personal safety ? These prohibitions does not apply in circumstances where Our People have a genuine concern for their personal safety or that of a colleague with whom they are in company with and as a consequence, offers or meets a demand for a payment, whether in connection with their employment or not.
Reporting of demands
Our People must report an approach for, or a demand for prohibited payments to the Business Leader as soon as practicable using the company incident reporting process and documentation.
Responsibilities
Our People including all levels of xyz leadership are responsible for regularly communicating, the Anti Bribery and Corruption policy, the Prohibited Actions and the requirements for reporting any demands made, to all Our People under their leadership, using the established communication channels.
Our People must keep complete and accurate business records including financial, human resources, payroll and environmental records. Our People must not create false, misleading or artificial entries to conceal improper payments or corrupt activity.
Our People are required to ensure all expenses relating to hospitality, gifts and gratuities provided by xyz and its related entities, are accurately recorded in sufficient detail and entered into the business records of the company.
Training
xyz will provide regular training on the requirements of the Anti Bribery and Corruption policy, Prohibited Actions and reporting requirements. They will also receive regular training and on the consequences of breaches of the policy, Prohibited Actions and reporting requirements.
Consequences of Breaching the Policy and Subsidiary Requirements.
Bribery and corruption are serious offences under the laws of Australia and the laws of countries we operate in. Consequences of breaching the policy, making, offering to make, or authorising improper payments could expose Our People to criminal and civil penalties and will be regarded by the directors as serious misconduct for which disciplinary action will be taken which will include termination of engagement contracts relating to remuneration.
cheers