How does your organization prevent, detect, and address allegations or incidents of corruption and bribery? Please describe the procedures in place, indicate whether the investigators or investigating committee are independent from the management involved, and explain the process for reporting outcomes to your administrative, management, and supervisory bodies.
CSRD
This indicator requires you to disclose:
(a) Procedures for Preventing, Detecting, and Addressing Corruption and Bribery:
Describe the procedures in place to:
Prevent corruption and bribery (e.g., internal policies, compliance training, third-party due diligence).
Detect corruption and bribery (e.g., internal audits, whistleblower mechanisms, forensic accounting reviews).
Address allegations or incidents (e.g., disciplinary actions, legal proceedings, corrective measures).
(b) Independence of Investigations:
State whether the investigators or investigating committee are independent from the management chain involved in the alleged matter.
If applicable, describe how independence is ensured (e.g., external audits, independent ethics committees, legal oversight).
(c) Reporting Process to Governance Bodies:
Explain how investigation outcomes are reported to the administrative, management, and supervisory bodies, including:
Frequency of reporting (e.g., quarterly, annually).
Level of transparency and oversight in governance structures.
Any formalized reporting frameworks in place.
https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html#d1e39710-3-1
Also in
G1-3 - Prevention and detection of corruption and bribery
- If your organization does not have procedures in place to prevent, detect, and address allegations or incidents of corruption and bribery, please confirm this and provide details on any plans or timelines for adopting such procedures.
- How does your organization communicate its policies to relevant stakeholders to ensure they are accessible and well understood? Please describe the methods and channels used, as well as any training or awareness initiatives implemented.
- How does your organization approach anti-corruption and anti-bribery training? Please describe the nature, scope, and depth of your training programs, indicate the percentage of functions-at-risk covered, and explain the extent to which members of your administrative, management, and supervisory bodies participate in these programs.