Corruption undermines trust, fairness, and sustainable development. This guide helps companies craft an anti-corruption policy tailored to their operations, grounded in international standards and best practices, to clearly communicate their stance and responsibilities.
⚡️ Quick summary
Set a clear tone at the top: Senior leadership must approve, own, and enforce the policy across the organization.
Be specific and practical: Avoid vague or overly technical language. Make the policy realistic, readable, and relevant to your business.
Cover all corruption risks: Include bribery, extortion, money laundering, political donations, and third-party risks.
Define enforcement & review: Spell out consequences of violations and commit to regular reviews and improvements.
An anti-corruption policy is a common way to communicate the company’s commitment and statement on how it seeks to meet its responsibilities to prohibit and eliminate corruption in all its forms. All companies can contribute to eliminate corruption, and the OECD's guidelines for multinational enterprises includes a chapter to bribery and corruption.
The OECD guidelines promote that companies should not, directly or indirectly, offer, promise, give, or request bribes which includes both bribery of public officials and employees of business partners. When companies implement anti-corruption policies and practices that enables positive contributions to economic, environmental, and social progress at the same time as reducing adverse impacts on the environment, social and governance matters.
It is important to emphasize that corruption is not only bribery, but can also be money laundering, extortion, embezzlement and misuse of sponsorships and charitable donations. Several international anti-corruption conventions have been adopted by the United Nations and the OECD, including United Nations Convention Against Corruption and the OECD’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
The policy is usually communicated internally within the company and externally to customers, suppliers, stakeholders such as investors/shareholders, service providers and civil society. One objective of having an anti-corruption policy is that then whole company learns and understands what kind of societal and other impacts the organization faces and contributes to. Another one is regulatory as bribery is criminalized in most jurisdictions.
Please note that there is no set format for what an anti-corruption policy should look like. Therefore, the policy can and should be specific to the company and relevant to its activities. It may also be integrated with other policies, such as compliance or political donations, depending on the company’s size and activities.
A successful policy should be
Realistic, achievable, and relevant to the company’s activities and size.
At most one or two sheets of A4.
Written in easily understandable language – Make complex issues into clear and understandable language when possible.
Publicly available and dated for transparency reasons.
Approved at the most senior level/top management, and they should also be responsible for implementing the policy throughout the whole company, including ensuring everyone understands the requirements of and works along the policy.
The consequences of violations of the policy should be spelled out clearly in the policy.
Developed by engagement with anti-corruption experts and lawyers as appropriate.
The organization's policy must include
General information of the company's mission - which provide the necessary background for the overall policy
Policy commitment - An explicit commitment, understood at a minimum as the OECD Guidelines for multinational enterprises and relevant United Nations conventions, that the company, complies with the framework of laws in the countries in which they operate, and in consideration of relevant international agreements, principles, and standards, take due account of the need to promote anti-corruption and prohibit corruption in all its forms
Requirements - The company's expectations that the workforce abide by the policy, as well as suppliers, and other stakeholders such business partners and third-party actors
Encouragement of stakeholders and suppliers – to implement the company’s anti-corruption practices, standards, and targets
Implementation processes - How the company implements the environmental policy within the company and through other business relations, e.g., communication and training.
Compliance – with all relevant anti-corruption legislation
Consequences of policy violation – should be spelled out clearly in the policy
Continual improvements – The company must have processes in place to monitor the impact of its anti-corruption policy, including registering data on violations. It should be reviewed regularly to ensure legitimacy and relevance with evolving legislations.
The organization's policy can be adopted to suit the particular business activities of the company. All companies have different impacts and legislative context depending on its operation, sectors and location. The company’s policy should be tailored to its activities, and in particular if it operates in a high-risk sector or countries. The following corruption topics are commonly included in a company’s anti-corruption policy: bribery, extortion, facilitation payments, political donations, money laundering and due diligence pertaining to the hiring, as well as the appropriate and regular oversight of agents and other third-party actors.
Please note that a policy or any policy is not a 100% solution for avoiding or mitigating potential/actual negative impacts. But it is a good first step for communicating what is expected internally, for business relationships, and external stakeholders to understand the issues facing the company, and how to act on them.
Example of don'ts in an anti-corruption policy
The policy does not outline what the company does, it’s too general and the reader can’t understand what context the company operates in and thereby can't understand the full picture of the corruption issues and risks that the company face.
Suppose the language is too complex and can only be understood by a lawyer or an expert. This makes it hard for employees to understand what their obligations are.
Not specific enough – “We are working towards lower corruption” – must include a clear message of the company’s zero tolerance for any form of corruption.
No information on the consequences of violation of the policy.
Signed by the wrong person.