(Quick Tips)Essential components of an effective anti-corruption programme for private companies

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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).
  6. 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.
  7. 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.