7.4 - Communication : Policy availability and communication

The ISO 37001 Anti-Bribery Management Systems standard, instituted by the International Organization for Standardization in 2016, directs organizations globally in fortifying their anti-corruption frameworks. This standard is pivotal for both private and public entities of any size, focusing on active prevention, detection, and management of bribery risks.

How to Answer the Question

Organizations can ensure that their anti-corruption policy is available and communicated effectively through the following steps:

1.   Policy Accessibility  :

  -   Universal Availability  : Ensure the anti-corruption policy is accessible to all personnel and business partners through multiple platforms (e.g., company intranet, email distributions, physical copies at offices).

  -   Translation  : Provide the policy in multiple languages relevant to the organization's operations to ensure all stakeholders understand the policy.

2.   Targeted Communication  :

  -   Risk-Based Approach  : Identify personnel and business partners who present a "more than low" risk of corruption and target communications specifically to them.

  -   Direct Communication  : Use direct methods such as emails, personal briefings, and dedicated training sessions to communicate the policy to high-risk groups.

3.   Regular Updates and Reminders  :

  -   Schedule Regular Updates  : Communicate any updates to the anti-corruption policy regularly.

  -   Reminders  : Send periodic reminders and refresher information to keep the anti-corruption policy top of mind for all relevant parties.

Why It's Important

Effective communication of the anti-corruption policy is crucial for:

-   Ensuring Compliance  : Helps ensure that everyone is aware of their responsibilities and the standards expected of them, thereby fostering compliance with the policy.

-   Mitigating Risks  : Targeted communication to high-risk personnel and partners significantly reduces the potential for corruption and misconduct.

-   Promoting a Culture of Integrity  : Demonstrates the organization's commitment to integrity and ethical behavior, influencing the overall corporate culture.

Examples

-   Example A  :

 -   Context  : A multinational corporation with operations in multiple countries.

 -   Action  : Translates its anti-corruption policy into all primary languages spoken in its various regions and distributes it via regional managers during local training sessions.

 -   Outcome  : Enhanced understanding and compliance with the anti-corruption policy across all regions.

-   Example B  :

 -   Context  : A company identifies its procurement team as high-risk due to their frequent interaction with suppliers.

 -   Action  : Provides specialized training sessions on the anti-corruption policy, supplemented with quarterly workshops and direct email communications.

 -   Outcome  : Increased vigilance and reporting of unethical practices within the procurement team.

For further resources on effective policy communication and implementation:

- [Agence Française Anticorruption](https://www.agence-francaise-anticorruption.gouv.fr)

- [OECD Guidelines on Corporate Governance of State-Owned Enterprises](https://www.oecd.org)