5.1.1 - Control over implementation and effectiveness

Organizations need to implement effective measures to ensure that their strategy and anti-corruption policy are aligned. This alignment is crucial for creating a cohesive approach to preventing, detecting, and addressing corruption within the organization.

How to Answer This Question

1.   Establishment of Oversight Bodies  : Describe how your organization has set up committees or oversight bodies such as an Ethics Committee or a Surveillance Committee, as mentioned in your Code of Ethics or compliance frameworks like Model 231G. These bodies should have the authority to oversee, review, and guide the anti-corruption efforts according to the strategic goals of the organization.

2.   Regular Review and Updates  : Outline the processes in place for the regular review of the anti-corruption policy and strategy to ensure they remain relevant and effective. This includes how often the policies are reviewed and under what circumstances (e.g., changes in law, business operations, or after a compliance breach).

3.   Integration of Policy and Strategy  : Explain how the anti-corruption policy is integrated into the broader strategic objectives of the organization. This might involve linking the policy with business objectives, risk management processes, and performance metrics to ensure a unified approach to corruption prevention.

Why It’s Important

-   Consistency and Cohesion  : Ensuring that the strategy and anti-corruption policy are aligned helps maintain a consistent approach across all levels of the organization. This alignment reinforces the importance of anti-corruption measures and ensures that they are embedded within the corporate culture.

-   Enhanced Compliance  : Alignment between strategy and policy aids in meeting both internal compliance standards and external legal requirements, reducing the risk of legal penalties and reputational damage.

-   Effective Resource Allocation  : When strategy and policy are aligned, resources can be more effectively allocated to areas of highest risk, enhancing the overall efficiency and effectiveness of the anti-corruption management system.

Examples

-   Example A: Large Multinational Corporation  

 -   Context  : Operates in multiple high-risk jurisdictions.

 -   Action  : Established a global compliance office responsible for integrating and aligning anti-corruption policies with business strategies across all regions. Regularly conducts risk assessments to ensure that both strategy and policy address the specific risks in different markets.

-   Example B: Small to Medium-Sized Enterprise (SME)  

 -   Context  : Engages in international trade with varying levels of bribery risk.

 -   Action  : Developed a streamlined anti-corruption policy that directly supports strategic business objectives, such as entering new markets. Uses annual strategy reviews to adjust policies, ensuring they remain aligned with the evolving business landscape and regulatory environment.

For further guidance on aligning your anti-corruption strategy with your policy, consider these resources:

-   Agence Française Anticorruption  : [Guide on corporate anti-corruption compliance](https://www.agence-francaise-anticorruption.gouv.fr/)

-   Anti-Bribery Guidance | Transparency International  : [Tools and tips for maintaining anti-corruption governance](https://www.antibriberyguidance.org/)

These resources offer comprehensive advice and best practices on creating and maintaining effective anti-corruption strategies that are aligned with organizational policies.