5.2 - Anti-bribery policy : Explicit prohibition of corruption

ISO 37001

How to Answer the Question

To effectively answer whether the anti-corruption policy explicitly prohibits corruption and ensures compliance with applicable laws, include:

-   Policy Details:   Describe the specific clauses in the anti-corruption policy that explicitly prohibit all forms of corruption, including bribery, fraud, and other corrupt activities.

-   Legal Compliance:   Explain how the policy aligns with national and international anti-corruption laws to which the organization is subject. Mention any legal frameworks or guidelines that the policy adheres to, such as the FCPA (Foreign Corrupt Practices Act) or the UK Bribery Act.

-   Implementation and Monitoring:   Discuss the measures in place to implement these policies, including training programs, monitoring systems, and internal audits.

For an in-depth guide on creating such policies, consult the [Agence Française Anticorruption](https://www.agence-francaise-anticorruption.gouv.fr).

Why It's Important

The explicit prohibition of corruption in organizational policies is crucial because:

-   Ensures Legal Compliance:   Helps the organization stay compliant with various anti-corruption laws and regulations, avoiding legal penalties and sanctions.

-   Promotes Ethical Culture:   Reinforces a culture of integrity and ethical behavior within the organization, which is vital for maintaining trust with stakeholders.

-   Prevents Corruption Risks:   Provides a clear framework for preventing, detecting, and responding to corruption, thereby protecting the organization from potential financial and reputational damage.

Further insights can be gained from [European Union’s legislation on anti-corruption](https://home-affairs.ec.europa.eu).

Examples

-   Example A:  

 -   Context:   A telecommunications company includes a detailed anti-corruption clause in its corporate governance manual, clearly prohibiting any form of bribery and mandating compliance with international anti-corruption laws.

 -   Resources Deployed:   Regular training sessions, an annual compliance review.

 -   Outcome:   Successful navigation of international projects without legal infractions, and high compliance ratings in external audits.

 Learn more about anti-corruption training at [OECD’s Corporate Anti-Corruption Compliance](https://www.oecd.org).

-   Example B:  

 -   Context:   A health sector NGO aligns its anti-corruption policies with both local and international health regulations, specifically prohibiting any unethical influence in pharmaceutical approvals.

 -   Resources Deployed:   Compliance officer appointments, whistleblower mechanisms.

 -   Outcome:   Enhanced transparency in operations and increased trust among donors and partners.

 Guidelines for integrating international standards can be found at [Kaspersky’s Global Anti-Corruption Compliance Policy](https://www.kaspersky.com).