5.5.1.2 Private regulation

Self-regulation usually takes place by adopting or endorsing a code of conduct that prohibits corruption, such as those listed in section 5.4.1. For instance, the ICC Rules on Bribery identify self-regulation by international business as a critical step in the fight against corruption.1 These ICC Rules call on companies to draw up their own codes, consistent with the ICC Rules and tailored to the particular circumstances of their business. However, they also ask companies to go beyond simply developing codes of conduct, which is seen to be merely the first step in the anti-bribery programme. To make their codes effective, companies are urged to develop clear compliance policies, guidelines and training programmes for implementing and enforcing their codes. "Acode without an effective follow-up programme may be regarded as simply a public relations exercise, having no teeth and serving essentially to reassure shareholders and to provide a cover for corporate management if violations occur."2

In order to increase compliance with a code of conduct, and in order to make its own conduct more transparent, a company can also publish a voluntary sustainability report. In doing so, it is the most practical to follow the GRI G3 reporting guidelines as these are the most widely used guidelines for sustain-ability reporting and are fast becoming the global standard. The company should include information on corruption-prevention programmes in its sustain-ability report. E.g. the GRI G3 guidelines suggest that companies make the following disclosures:

These three disclosures will show how the company tries to prevent corruption, thereby stimulating the company to implement adequate measures.