Counteracting bribery. ISO 37001:2016

Counteracting bribery: Currently the Respect Index includes 25 companies listed on Warsaw Stock Exchange. The largest of them [1] (i.e. 9 out of 10 largest) follow non-financial reporting GRI G4 Guidelines – by implication, they have undertaken to provide the total number and types of confirmed cases of bribery together with their implications. Six out of ten of the largest companies have not identified any instances of bribery, and two have not referred to this matter in their reports for 2015 or the previous years [2].

Hence the question: why companies do not detect any instances of bribery? This issue is significant, especially since starting from 2017, counteracting corruption will no longer be an internal problem for approx. 300 Polish enterprises.[3]

In line with the amendments to the Accounting Act, the financial statements prepared for the year starting 01 January 2017 or later will need to disclose information about the policy applied as regards counteracting corruptive practices and the outcome of applying such policies (non-financial reporting).

The obligation above will apply inter alia to banks, cooperative savings and loan unions (SKOK), insurance companies, listed companies, payment institutions, brokerage houses, investment funds, and open pension funds (OFE), if they:

  • employ over 500 people,
  • their balance total in the current and previous year equals PLN 85 million or more, or
  • their net revenue equals more than PLN 170 million,
  • PLN 102 million and 204 million respectively for consolidated statements.

It is not enough to create a sound anti-corruption policy on paper – you need to show your investors that the policy is followed with telling effect and it exerts a positive impact on the goodwill. Indicating that no instances of bribery or fraud are detected for several years in a row may seem suspicious and discredit anti-corruption efforts of the company taken in Polish business reality.

Counteracting bribery – ISO 37001:2016

At the end of last year management and supervisory bodies of companies that want to counteract corruption effectively acquired a new tool – i.e. ISO 37001:2016 Anti-bribery management systems – Requirements with guidance for use. The new norm provides excellent guidance for introduction of an anti-bribery management system or alternatively, it can be treated as a checklist when auditing the company’s current system. The audit may cover an individual department (e.g. procurement), a process (e.g. investment processes), a group of contractors (e.g. intermediaries) or selected projects/ transaction types (e.g. preparation of terms of reference, commissions).

In our future posts we will discuss effective counteracting of bribery in business dealings in more detail. We wish you pleasant reading.

[1] The largest Respect Index companies in terms of their % share as at December 2016

[2] Annual/integrated/CSR reports for 2015, for 3 companies – reports for 2013-2014 (biannual reporting) and for 1 company – report for 2014.

[3] Information from:, of 07 March 2017

Related posts

Leave a Reply

Your email address will not be published. Required fields are marked *