Corruption is caused by three major problems: dishonest persons, gaps in legal regulation and insufficient processes. Therefore, both in analysing the current situation and creating anti-corruption measures, they should be grouped by corruption issue they target.




The major principles to be followed by business striving for creation of anti-corruption environment are:

  1. Publicity and openness;
  2. Transparency and clear procedures;
  3. Honesty;
  4. Loyalty and reliability;
  5. Awareness and integrity;
  6. Encouragement to refrain from taking and giving bribes as well as to report and show zero tolerance for dishonest behaviour.
  7. "Four eyes" principle for control and monitoring[69].


Further on this Handbook discusses the most commonly-used corruption prevention methods and the aspects of their application:

  1. The role of management in anti-corruption activities;
  2. Organisation's anti-corruption policy;
  3. Assessment of risks of corruption, which may be encountered by an organisation in its business environment;
  4. Investigation of tolerance for corruption and unethical behaviour among employees;
  5. Assessment of honesty and loyalty of prospective employees;
  6. Anti-corruption education for staff;
  7. Codes of Ethics and Conduct;
  8. Policy for managing conflicts of interest;
  9. Gifts and representation policy;
  10. Policy for charitable donations and sponsorships;
  11. Lobbying policy;
  12. Reporting system and whistleblower protection;
  13. Checks on business partners;
  14. Transparency and accountability to the public;
  15. Organisation of anti-corruption activities;
  16. Preparation, implementation and review of anti-corruption programmes;
  17. Maturity assessment of the organisation's corruption prevention system.


6.1. The Role of the Management in Anti-Corruption Activities


Organisational culture that is transparent, honest and based on values is especially important in developing organisation’s activities on the basis of high ethical standards and giving no opportunity to corruption. The message of intolerance for corruption should reach every staff member of the organisation.

The most important role of combating corruption falls on the management of the organisation, the example of which, active involvement and commitment, ensures the creation of an effective anti-corruption programme and its consistent implementation at the organisation.

The duty of the management is to initiate the implementation of the anti-corruption programme in the organisation, to be actively involved in its creation and selection of the required measures. The anti-corruption policy and the anti-corruption programme should be approved by the decision of the management (the board of the company or the director, where the organisation does not have a board), thus providing it with the necessary strength and emphasizing their importance to the organisation.


Do as I do, not as I say


The management must not only declare its determination to combat corruption, but also regularly promote compliance with the highest standards by showing their personal example — their position must be clear and up-front to   everybody. The top-management behaviour is particularly important in formation of the attitude of the middle management and all the staff of the organisation in combating corruption.

The management should promote their staff education and development of competencies in combating corruption, also value internal discussions, where the staff could discuss problem situations, possible solutions, gain equal understanding of what is acceptable and what should be clearly rejected in the organisation.

The management of the organisation should also participate in periodic assessments of potential corruption-related risks, improving the anti-corruption programme and defining measures for threat reduction.

If the organisation decides to appoint an employee or a department to conduct the implementation of the organisation's anti-corruption programme, the management should provide them with appropriate authorisations of discrete and independent action, enabling them to influence processes and participate in discussions on relevant transactions.

Such appointed person (department) should be accountable directly to the management and, if necessary, be able to contact the management.

[69] http://www.youtube.com/watch?v=2purKpLrTR4;