6.15. Organisation of Anti-Corruption Activities


Anti-corruption activities should be organised according to the size of the organisation, its area of activities and region, the likely scope of corruption-related risks, organisational structure, distribution of responsibilities, objectives and other characteristics.

Large companies usually implement the most extensive anti-corruption programmes, while smaller companies may use measures that are simpler, but nevertheless ensure focus on combating corruption.

In cases, where the preparation of an anti-corruption programme involves external assistance, it is very important to ensure active involvement of the company’s employees who would acquire the necessary knowledge as well as understand the relevance and responsibility  of these measures.

Depending on the size of the organisation, a person or a unit may be assigned to govern its anti-corruption programme. It is essential that such a person or unit  is independent of other business units and accountable directly to the top management of the organisation. The assigned person or unit should be responsible for the preparation and implementation of the anti-corruption programme, its dissemination, regular  monitoring and improvement of the programme.


The draft anti-corruption programme should be presented to various units of the organisation, broadly discussed by hearing out the comments, remarks and proposals of employees on what measures might be the most effective in the case of a specific organisation.

In addition, it would be expedient to invoke the expertise  and experience of a law unit or internal audit unit in order to assess as much as possible inherent risks of the organisation and apply  effective measures.

It is also relevant to discuss the situations related to corruption, bribery and dishonest actions that have already happened, consider the possible ways for prevention of such situations and what measures should be taken if an analogous problem reoccurs.

The organisation may disseminate information on the anti-corruption programme under implementation, its progress and the measures applied the organisation on its  Intranet page, it may also use handouts, e-mail messages as well as staff training aids and programmes.

In preparation for the implementation of the anti-corruption programme, it be would be helpful to meet with  the representatives of other organisations that have already implemented such programmes — to listen to their experience, learn what measures were particularly successful and brought good results as well as which situations were the most complicated ones and how they managed to tackle them.

Organisations may also use information provided, research/surveys, analyses  as well as measures recommended by non-governmental organisations.