Disclosure Requirement G1-3 – Prevention and detection of corruption and bribery

  1. The undertaking shall provide information about its system to prevent and detect, investigate, and respond to allegations or incidents relating to corruption and bribery including the related training.

  2. The objective of this Disclosure Requirement is to provide transparency on the key procedures of the undertaking to prevent, detect, and address allegations about corruption and bribery. This includes the training provided to own workers and/or information provided internally or to suppliers.

  3. The disclosure required under paragraph 16 shall include the following information:

    • (a) a description of the procedures in place to prevent, detect, and address allegations or incidents of corruption and bribery;

    • (b) whether the investigators or investigating committee are separate from the chain of management involved in the matter; and

    • (c) the process, if any, to report outcomes to the administrative, management and supervisory bodies.

  4. Where the undertaking has no such procedures in place, it shall disclose this fact and, where applicable, its plans to adopt them.

  5. The disclosures required by paragraph 16 shall include information about how the undertaking communicates its policies to those for whom they are relevant to ensure that the policy is accessible and that they understand its implications.

  6. The disclosure required by paragraph 16 shall include information about the following with respect to training:

    • (a) the nature, scope and depth of anti-corruption and anti-bribery training programmes offered or required by the undertaking;

    • (b) the percentage of functions-at-risk covered by training programmes; and

    • (c) the extent to which training is given to members of the administrative, management and supervisory bodies.