Objective
To ensure companies understand the relevance of anti-bribery and corruption (ABC) controls within responsible sourcing and take appropriate steps to prevent and address corruption-related risks.
Why This Matters
Corruption can obscure supply chain transparency, distort risk assessments, and undermine efforts to identify and mitigate human rights or environmental risks. Even small facilitation payments can lead to legal liability or reputational harm.
Key actions checklist
- Develop an anti-bribery and corruption policy
Set out your company’s zero-tolerance approach. Apply to both employees and business partners. - Screen suppliers for corruption red flags
As part of supplier onboarding and KYC, assess whether suppliers operate in high-risk jurisdictions or have regulatory violations. - Train relevant staff
Provide basic training to employees in procurement, sourcing, or supplier engagement. - Include ABC clauses in contracts
Ensure supplier agreements contain clear anti-bribery clauses and termination provisions. - Establish a reporting mechanism
Ensure your grievance/whistleblowing mechanism covers bribery and corruption concerns. - Set up a gifts and hospitality register
Implement a log to record gifts or hospitality offered or received. Define thresholds. - Monitor and review
Maintain a record of any corruption-related red flags or incidents and periodically review.
Facilitation Payments
Facilitation payments — sums paid to obtain preferential treatment — should be strictly prohibited. Staff asked to make a facilitation payment should immediately report this.