6.16. Preparation, Implementation and Review of an Anti-Corruption Programme


Preparation of an anti-corruption programme


The preparation of  broad anti-corruption programmes in small business organisations would be irrational due to the small number of their employees and simpler business procedures; however, the larger business organisation, the more complex procedures in it, and it has more contact points externally, thus, accordingly, also has higher corruption risk factors. Therefore,  it is reasonable to provide for  all anti-corruption measures, their target addressees, deadlines and persons responsible for their implementation in a single anti-corruption programme[105].

An anti-corruption programme must include only those risk areas and elements that are relevant to an individual  organisation, directly related to its activities and were identified during risk assessments.

It is much better to start with a potentially  incomplete programme, which covers at least the major risk  areas, and then continue completing and adjusting it in the course of time than to have no programme at all.


The main focus of such programme should be on the following key aspects:

  • identifying the major risks;
  • including evaluation of risk sources and conditions  into daily operations;
  • defining possible forms of corruption, risky situations and mitigating measures;
  • defining  the risk of corruption in business market relations, property relations and purchases as well as specifying mitigating measures.


An anti-corruption programme should have an appropriate tone and structure:

  • ensure an appropriate "top-down" tone from the top management;
  • approve the policy of zero-tolerance to corruption;
  • develop compliance culture;
  • include compliance culture into staff policies (training, employment, evaluation of achievements, promotion and disciplinary actions).


In order to decrease the risk of violations, the anti-corruption programme must define control mechanisms, and the control procedures for high-risk processes should be approved and regular monitoring thereof should be carried out.


The programme should raise its awareness, ensure  compliance, its observance and  implementation by:

  • planning mandatory all-level staff training;
  • implementing disciplinary measures and incentives;
  • implementing reporting requirements and motivating elements to maintain compliance;
  • practising mandatory training for employees in risky positions, partners, contractors or suppliers;
  • introducing anti-corruption provisions in business contracts.


The anti-corruption programme must be up-to date and adapt to any changes in the organisation by:

  • considering and implementing changes in rules, financial operations, policies and procedures;
  • implementing changes necessary for entering new markets and business segments;
  • implementing adjustments based on the experience in  the programme implementation.


Implementation of an anti-corruption programme


The preparation of an anti-corruption programme is then followed by its implementation in the organisation.

Along with the group of employees, the task of which is to implement the anti-corruption programme, several other segments of the organisation, namely, the management and communication specialists, should also be involved to achieve the successful implementation of the programme. The leadership of the  programme implementation should be assigned to the employees  appointed on the basis of  their personal traits, dutifulness, trust and reliability that they possess  at the organisation as well as taking into account how well they  would be able to represent the implementation of the programme.

The programme must be implemented as a project — consistent with the organisation's type of activities, budget, action plans and progress checks. The implementation process might be easier if the anti-corruption programme is included into the processes that are already taking place in the company. This would also require ensuring that the anti-corruption measures do not become fragmented, unclear and unnoticeable actions.


Communication is the milestone of the development of the anti-corruption programme. For this purpose organisations should prepare a general communication plan. During the implementation of the programme employees should be introduced to the new requirements and clearly know where they may obtain more information. Information should be available on the organisation's Intranet or in a printed format.

It is recommended that during the implementation of the programme  one person or a specific group of  persons  is appointed to answer the questions. Different methods may be applied for reinforcement of  the implementation of the programme, for example, managers of several levels certify in a writing that they received the information related to the programme and undertake obligations to implement it.

The head of the organisation and its board or board of directors/management board should ask  the various units to submit reports on the implementation and compliance of the programme on a regular basis.

The top management should demonstrate its support to the implementation of the programme, for example, via the company’s reports published on the Intranet and presented during the staff meetings related to the development of the programme.

The top management of the company should also ensure a high-quality implementation of the anti-corruption  programme.


Generally, the communication of the anti-corruption programme and the company rules prohibiting the intensity of corrupt actions may  provide a  huge preventive effect, for instance,   many violations occur due to the lack of awareness and ignorance.

During the preparation, implementation and further development of the programme, information on  the plans, content and requirements under the programme should be regularly communicated to the employees and updated.


The internal communication measures in the company, especially those that are specially prepared  for the implementation of the anti-corruption programme, may include:

  • an e-learning programme;
  • a help line on ethical issues;
  • meetings and exchange of ideas;
  • e-mails from the director general to the staff;
  • information from the company's lawyers and ethical supervisors.


In order to ensure the efficient implementation of anti-corruption activities, it is necessary to conduct the evaluation and monitoring of the implementation of the programme by carrying out such activities as risk analysis, analysis of newly-adopted national legal acts regulating the organisation's activities and analysis of internal legal acts within organisation itself as well as continue further training.

It should be endeavoured to harmonise the monitoring of anti-corruption activities with other business processes. Risk assessment is the starting point for setting anti-corruption priorities, it might be coordinated and implemented as a general part of the risk review.

It is essential  to take an adequate in-depth  approach  to  corruption-related objects and issues in order to respond to them in an adequately specific and proper manner.

Having identified the anti-corruption activities, which occurred  after risk assessment, they should be integrated into the business plans for the nearest period. It is crucial to include the corruption-related issues into the agenda of  different-level meetings of the company on a regular basis.

The head of the organisation should regularly inform the board (in absence of the board, the shareholders) on how the anti-corruption programme works in practice. The administration’s  responsibility  is regularly monitoring whether  all planned activities are implemented. The best way to do that is through monthly, quarterly or semi-annual company meetings, which are jointly organised by the administration and units as well as  business entities.

The greatest attention should be focused on how the agreed measures are implemented. Moreover, the company's internal and external changes (such as new procedures and other documents) must be reviewed and evaluated in order to determine if the agreed measures remain relevant.

It is also important to inform about any cases of attempted corruption and incidents of corruption, “nearly happened” corruption events, including information on how these cases were tackled. All this information  is relevant in considering if the measures should be continued or if the programme requires improvement.

Along with this regular  monitoring it would be expedient, for instance, that the heads of appropriate units of organisations  each year signed the obligation on  the implementation of anti-corruption activities in their unit, including planned training, measures to be implemented under the plan, etc. The heads should also monitor the implementation of the programme and regularly inform about  the progress, achievements and incidents, should there be any.

This would ensure a natural "bottom-up" process, when the heads of units  report about the anti-corruption activities through  different levels of administration up to the director general. Later on the director general might submit such reports to the board (shareholders).


Review of an anti-corruption programme


It is important to create an approach to the anti-corruption programme as a part of constant improvement, caused by changing external and internal factors in the company. Along with regular monitoring, which manifests through identification and implementation of specific measures, it would be normal that  the  management initiates a formal evaluation of the programme.

Commonly, this would comprise the adequacy assessment (content and model) and compliance (efficiency) assessment.

The adequacy assessment of the programme requires the precise  assessment criteria.

There are various standards and good practice, which might be useful. Transparency International has a Self-Evaluation Tool and an Assurance Framework, which defines an external review methodology. Both documents are available on Transparency International website.

Large auditing and consulting companies have their own voluntary defined good practice following which they may  evaluate  companies' programmes. In evaluating the  structure of the programme, the assessment of actual compliance is not desirable  (i.e. if the document or measure exists or not) — the programme should be substantiated by documents and specific tests should be carried out  in order to determine that the programme is implemented under the plan.

A need for an independent evaluation depends on the fact if the programme is subject to internal evaluation  at the company or  external resources will be used. In some cases the management may require an independent evaluation of the anti-corruption programme.

The internal audit function is adequate  for the independent evaluation, where the  external advisers are not desirable. By  using external advisers, the company may benefit from their experience and best practice examples   accumulated  in other companies.

It is of major importance for the external advisers to have a good understanding of the company's business nature and that  their assessments, considerations and recommendations are adequate  and proportionate to the company's risk situation and needs.

[105] Lithuanian Dictionary defines a programme as a plan of action and its printed or otherwise publication.

In preparation of an anti-corruption programme in a business organisation  the Guidelines for the Preparation of a Corruption Prevention Programme in a State Institution, approved by  STT Director Order No. 2-100 of 3 April 2014 may be partially followed, which are available here: https://www.e-tar.lt/portal/lt/legalAct/50865870bb0111e38766a859941f6073