Global Anti-Bribery Guidance

Best practice for companies in the UK and overseas

2. Governance & Commitment

Quick Read

The board should provide oversight of the implementation of the anti-bribery programme, ensuring it receives regular reports from management and the results of internal and external audits and direct that necessary changes are made.

The role of the board is critical in ensuring the establishment of a control environment in order to ensure the anti-bribery programme is effective.  The control environment is the set of standards, processes, and structures that provide the basis for carrying out internal control across the organization.  The control environment provides the setting in which the anti-bribery programme operates. Without such an environment, the anti-bribery programme will operate in isolation without an appropriate organisational framework and suitable systems. 

The control environment is also supported by an anti-bribery commitment, a process to identify and comply with anti-bribery and related laws, clear assignment of responsibilities for the anti-bribery programme and ensuring that the programme takes into account the company’s organisational structure.

Key elements:

  • Commitment: The board commits to ethics and integrity values and to ensuring a corporate culture that lives up to them.
  • Alignment: The board ensures the anti-bribery policy and programme are an expression of the corporate values.
  • Oversight: Governance and oversight is provided by the board to the anti-bribery programme.
  • Structure: The organisation structure, systems and management approaches support the implementation of corporate values and the anti-bribery programme.