This metric is intended to capture if the organization identified insufficiencies in action taken to address breaches in procedures and standards of anti-corruption and anti-bribery that took place during the reporting period.
Insufficiencies in action taken to address breaches in procedures and standards of anti-corruption and anti-bribery refer to shortcomings or inadequacies in the measures put in place to prevent, detect, and address corrupt or fraudulent practices within an organization. Examples include:
Lack of clear anti-corruption policies and procedures: Without clear and comprehensive policies and procedures in place, employees may not know what constitutes corruption or bribery, or how to report such activities.
Inadequate training: Employees may not have received the necessary training to recognize and report corruption or bribery, or to follow anti-corruption policies and procedures.
Insufficient monitoring and enforcement: An organization may not have adequate systems in place to monitor and enforce compliance with anti-corruption and anti-bribery policies and procedures.
Limited internal audit and investigation: An organization may not have an adequate internal audit and investigation process in place to detect and address potential corruption or bribery.
Inadequate risk management: An organization may not have effective risk management systems in place to identify and mitigate risks related to corruption and bribery.
Bribery is here defined as dishonestly persuading someone to act in one's favor by giving them a gift of money or another inducement.
Corruption is here defined as the abuse of entrusted power for private gain, which can be instigated by individuals or organisations. It includes practices such as facilitation payments, fraud, extortion, collusion, and money laundering. It also includes an offer or receipt of any gift, loan, fee, reward, or other advantage to or from any person as an inducement to do something that is dishonest, illegal, or a breach of trust in the conduct of the undertaking’s business. This can include cash or in-kind benefits, such as free goods, gifts, and holidays, or special personal services provided for the purpose of an improper advantage, or that can result in moral pressure to receive such an advantage.
For more information, see the following resource: https://www.efrag.org/Assets/Download?assetUrl=%2Fsites%2Fwebpublishing%2FSiteAssets%2F17%2520Draft%2520ESRS%2520G1%2520Business%2520Conduct%2520November%25202022.pdf