Controls also need to be accessible and tailored to all employees, across all divisions and areas of operation. Training forms a central part of this support system promoting an understanding of bribery and improper business conduct in order to develop employees’ capacity to identify, avoid and resist corrupt approaches.
Support to Employees
Does the company provide training on its anti-bribery and corruption programme to all employees across all divisions and geographies and in all appropriate languages?
Does the company provide tailored training on its anti-bribery and corruption programme for at least the following categories of employees:
a) Employees in high-risk positions
b) Middle management
c) Board members
Does the company measure and review the effectiveness of its anti-bribery and corruption communications and training programme?
Does the company ensure that its employee incentive schemes are designed in such a way that they promote ethical behavior and discourage corrupt practices?
Does the company commit to and assure itself that it will support and protect employees who refuse to act unethically, even when it might result in a loss of business?
Does the company have a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents?
Does the company provide multiple whistleblowing and advice channels for use by all (e.g. employees and external parties), and do they allow for confidential and, wherever possible, anonymous reporting?