Integrity System

Corruption can affect a company in many negative ways in terms of fines, lost business opportunities and a tainted reputation. It therefore needs to be treated as a risk and managed accordingly.

On this page you will find a guide that will help you establish and implement adequate procedures for managing corruption risks and to comply with international anti-corruption legislation. The guide is inspired by the US Sentencing Guidelines, the OECD Good Practice Guidance on Internal Controls, Ethics and Compliance, the Official Guidance to the UK Bribery Act as well as by ISO quality Management models and the COSO Enterprise Risk Management framework.

This Integrity System is divided into five guiding steps. You can navigate the steps by clicking on the images below and access the full description of each step from the text box or from the navigation list to the left.

Commit
Map
Implement
Communicate
Evaluate

Top Level Commitment

The successful set-up and implementation of an Anti-Corruption Integrity System requires full support from the company's top management.

Assess and Map Your Risks

Your company must primarily focus on managing the most serious corruption risks. Therefore, a comprehensive risk assessment must be performed by the person responsible for setting up the Integrity System together with employees familiar with the company's process and sales channels. After the risks have been identified, they should be weighted to help define priorities.

Practical Implementation

An Integrity System is not worth much only on paper. You need to make sure that the system is implemented through procedures and processes. An implementation mechanism must be put in place and specific measures must be implemented to mitigate the specific risks your company faces.

Communication and Training

When your Integrity System is in place and running, internal and external stakeholders need to be informed: Communication and training must be carried out to raise awareness about the System.

Evaluation of Integrity System

Complying with the policies and procedures of your Integrity System is a continuous exercise, and its effectiveness and relevance need to be evaluated over time. Some of the measures employed may prove irrelevant or your company may be exposed to new risks, prompting a new risk assessment. Your System therefore needs to be monitored to evaluate whether is serves its purpose in the best way possible.