The document is a revised version of the 2013 guide and reflects significant changes in the global environment, including digitalization, the development of artificial intelligence, tightening regulatory requirements, and growing expectations from society and investors. The updated Guide was developed in 2024-2025 within the framework of the Think Lab on Business Integrity, with the participation of more than 20 international companies and organizations, ensuring its practical orientation and alignment with current business practices.
A key innovation is the introduction of the concept of transformational governance, which is explored in the first chapter of the Guide. Under this concept, businesses are encouraged to go beyond mere legal compliance and adhere to broader standards of ethical conduct and social responsibility. This approach positions anti-corruption compliance as an integral part of sustainable development, closely linked to ESG issues, human rights, and transparency.
In the second chapter, the authors move from theoretical discussion to outlining three practical principles that should underpin the development and maintenance of anti-corruption ethics and compliance programmes. In particular:
- Integrated approach – embedding anti-corruption measures into the overall system of risk management and corporate sustainability;
- Stakeholder involvement – taking into account the views and interests of both internal and external stakeholders when designing and implementing compliance programmes;
- External engagement – adopting a proactive role in promoting business integrity, including transparency and participation in collective initiatives.
The third chapter provides detailed recommendations for designing and implementing anti-corruption programmes, covering key compliance elements, including:
- Leadership and fostering a culture of integrity (including the shift from “tone from the top” to ethical leadership). It emphasizes that effectiveness depends not on formal declarations, but on consistent leadership behavior, integration of anti-corruption objectives into corporate strategy, and the inclusion of relevant KPIs for management;
- Systematic corruption risk assessment, taking into account industry, geographic, and organizational factors. The Guide presents a step-by-step model based on ISO 31000, including: establishing the context, identifying risks, analyzing risks, evaluating risks, and determining mitigation measures. It is emphasized that such assessments should consider both internal and external factors, including industry specifics, geographic footprint, business structure, supply chains, and regulatory environment;
- Development and implementation of internal policies and procedures (anti-corruption policies, conflict of interest policies, and regulation of high-risk activities), with a focus on adapting them to business specifics, ensuring regular updates, and avoiding a purely formal approach;
- Training and internal communication, recommending regular, risk-based training, the use of practical scenarios, and continuous communication to reinforce the value of compliance;
- Mechanisms for detecting misconduct, including whistleblowing channels, with emphasis on confidentiality, protection of reporting persons, and building trust in these mechanisms;
- Monitoring, internal controls, and disciplinary measures, highlighting the importance of independence of control functions, consistency in response, and proportionality of sanctions;
- Evaluation of programme effectiveness and continuous improvement, including the use of performance indicators, regular monitoring, internal and external assessments, and adaptation to evolving risks and business conditions.
The Guide also emphasizes that an effective anti-corruption programme must be embedded in corporate culture, supported by leadership, and adaptable to changing risks and operating environments.
The final chapters focus on the external dimension of compliance. In particular, they address:
- Transparency and external communication, including public reporting on anti-corruption measures, with an emphasis on proactive disclosure, publication of policies, and building trust among investors, partners, and society;
- Participation in collective anti-corruption initiatives involving business, government, and civil society, highlighting their role in establishing common integrity standards, reducing corruption risks across sectors and supply chains, and fostering partnerships at both national and international levels;
- The use of digital technologies and artificial intelligence, covering both opportunities (automated monitoring, data analysis, detection of anomalies and suspicious activities) and associated risks, including algorithmic transparency, data bias, and the need for proper oversight.
