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Essential components of an effective anti-corruption programme for private companies
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Anti-corruption laws and regulations - All personnel, in particular the senior management of the company, should ensure that operations under their charge comply with all the laws and regulations, including the Prevention of Bribery Ordinance.
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Roles and responsibilities - Each personnel in the company should understand his role and responsibilities in helping the company adopt anti-corruption practices and implement its anti-corruption policy.
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Anti-corruption policy and Code of Conduct - Companies should state its commitment to ethical and anti-corruption practices in doing business, and its position and key measures against corruption. In particular, companies should promulgate a code of conduct setting out the ethical and probity requirements for directors and staff.
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Corruption risk identification and assessment - Companies should accord management of corruption risks an equally high priority as other business risks, and identify the risks through systematic reviews of company policies and procedures.
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Anti-corruption control - Companies should devise and implement internal controls to prevent or detect various forms of abuse, corruption and other malpractice based on the findings of the corruption risk reviews (point 4 above).
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Training and communication - Companies should promote an ethical, anti-corruption and compliant culture within the organisation through effective communication of the anti-corruption policy (point 3 above), and corruption prevention capacity building among the staff at all levels.
- Monitoring and review - Companies should monitor and review the anti-corruption programme, the corruption risks and effectiveness of internal controls in response to changes or corruption incidents.
