Anti-bribery and anti-corruption

The objectives relating to combating bribery and corruption are based on the general corporate objectives and are linked to the assessment of risks. An implemented management system for combating bribery and corruption covers the relevant sub-areas and defined rules.

You should ask yourself these questions:

• Do we derive our objectives and priorities for combating bribery and corruption from the results of a risk assessment?
• Do we communicate the respective objectives to the relevant target groups?

It is important to identify the risks that could lead to potential infringements, such as vulnerable business activities involving grants, donations and sponsorships. For example, when doing business with public officials in certain countries or regions, companies can use the Corruption Perception Index (CPI) to assess corruption in the public sector.

You should ask yourself these questions:

• Are the general and business-specific risks known and do we check them systematically and regularly?
• Have we entered into any significant contracts or joint venture arrangements with public entities or governments?
• Do we use sales intermediaries, consultants or business partners to generate sales?
• Have we checked the integrity of our business partners and intermediaries?

Guidelines, operating procedures and other measures to prevent or sanction violations are implemented in order to limit the identified bribery and corruption risks.

You should ask yourself these questions:

• Have we established specific policies and measures to ensure compliance?
• What legal provisions are we subject to, for example in relation to corruption?
• Do we have an anti-corruption policy?
• Do we have processes in place to monitor business relationships with public companies or their representatives?
• Are there processes and controls in place to ensure that all transactions and payments are properly documented and accounted for?

The management defines the roles, responsibilities and structures and provides sufficient resources for anti-bribery and anti-corruption tasks.

You should ask yourself these questions:

• Are the roles and responsibilities for compliance clearly defined? For example, have anti-corruption officers been appointed or has a compliance committee been set up?
• Is the compliance organisation equipped with sufficient powers?
• Who is the reporting submitted to and what is the number of employees and the annual budget in the assigned area?

The anti-bribery and anti-corruption programme – for example, in the form of a code of conduct or an anti-corruption policy – should be effectively communicated throughout the organisation. All employees must be aware of their responsibility.

You should ask yourself these questions:

• How have we communicated the relevant regulations to the executives, line managers and employees?
• How and at what intervals do we organise information events or training courses for executives/line managers, employees and sales people?
• Have we also informed external suppliers and business partners about the regulations and required them to comply with those regulations?
• Have we set up a whistleblower system that gives employees, business partners, customers and other stakeholders the opportunity to report infringements? Are employees familiar with that system and is it easily accessible to external third parties?

Businesses should continually monitor the appropriateness and effectiveness of anti-bribery and anti-corruption actions. Any weaknesses or infringements identified during the monitoring process should be reported to management and remedied.

You should ask yourself these questions:

• Do we have an appropriate and functioning internal control system that also covers ABAC areas?
• Are potential infringements investigated and mitigated?
• What consequences and improvement actions have we derived from the results of the investigation?
• Is the programme regularly reviewed and what are the background and results of that review?