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GRI 205: Anti-Corruption 2016

EFFECTIVE DATE: 1 JULY 2018

Introduction​

GRI 205: Anti-corruption 2016 contains disclosures for organizations to report information about their corruption-related impacts, and how they manage these impacts. The Standard is structured as follows:

  • Section 1 contains a requirement, which provides information about how the organization manages its corruption-related impacts.
  • Section 2 contains three disclosures, which provide information about the organization’s corruption-related impacts.
  • The Glossary contains defined terms with a specific meaning when used in the GRI Standards. The terms are underlined in the text of the GRI Standards and linked to the definitions.
  • The Bibliography lists authoritative intergovernmental instruments and additional references used in developing this Standard.

Background on the topic​

This Standard addresses the topic of anti-corruption. In this Standard, corruption is understood to include practices such as bribery, facilitation payments, fraud, extortion, collusion, and money laundering; the offer or receipt of gifts, loans, fees, rewards, or other advantages as an inducement to do something that is dishonest, illegal, or represents a breach of trust. It can also include practices such as embezzlement, trading in influence, abuse of function, illicit enrichment, concealment, and obstructing justice.

Corruption is broadly linked to negative impacts, such as poverty in transition economies, damage to the environment, abuse of human rights, abuse of democracy, misallocation of investments, and undermining the rule of law. Organizations are expected by the marketplace, international norms, and stakeholders to demonstrate their adherence to integrity, governance, and responsible business practices. These concepts are covered in key instruments of the Organisation for Economic Co-operation and Development and the United Nations: see the Bibliography.

1. Topic management disclosures​

An organization reporting in accordance with the GRI Standards is required to report how it manages each of its material topics.

An organization that has determined anti-corruption to be a material topic is required to report how it manages the topic using Disclosure 3-3 in GRI 3: Material Topics 2021 (see clause 1.1 in this section).

This section is therefore designed to supplement – and not replace – Disclosure 3-3 in GRI 3.

REQUIREMENTS​

  • 1.1 The reporting organization shall report how it manages anti-corruption using Disclosure 3-3 in GRI 3: Material Topics 2021.

RECOMMENDATIONS​

  • 1.2 The reporting organization should disclose the following information:
    • 1.2.1 The organization’s risk assessment procedures for corruption, including the criteria used in the risk assessment, such as location, activity, and sector;
    • 1.2.2 How the organization identifies and manages conflicts of interest that employees or persons linked to the organization’s activities, products, or services may have. Conflicts of interest for the highest governance body are covered in Disclosure 2-15 of GRI 2: General Disclosures 2021;
    • 1.2.3 How the organization ensures that charitable donations and sponsorships (financial and in-kind) that are made to other organizations are not used as a disguised form of bribery. Recipients of charitable donations and sponsorships (financial and in-kind) can include not-for-profit organizations, religious organizations, private organizations, and events;
    • 1.2.4 The extent to which communication and training on anti-corruption is tailored to those governance body members, employees, business partners, and other persons that have been identified as having a high risk of incidents of corruption;
    • 1.2.5 At which stage the training on anti-corruption for governance body members, employees, business partners and other persons that have been identified as having a high risk of incidents of corruption is provided (e.g., when new employees join the organization or when relationships with new business partners are established); and the frequency of the training (e.g., annually or biannually);
    • 1.2.6 Whether the organization participates in collective action to combat corruption, including:
      • 1.2.6.1 the strategy for the collective action activities;
      • 1.2.6.2 a list of the collective action initiatives in which the organization participates;
      • 1.2.6.3 a description of the main commitments of these initiatives.

GUIDANCE​

Guidance for clauses 1.2.4 and 1.2.5
In the context of this GRI Standard, the term ‘business partners’ includes, among others, suppliers, agents, lobbyists and other intermediaries, joint venture and consortia partners, governments, customers, and clients.

2. Topic disclosures​

Disclosure 205-1 Operations assessed for risks related to corruption​

REQUIREMENTS​

The reporting organization shall report the following information:

  • a. Total number and percentage of operations assessed for risks related to corruption.
  • b. Significant risks related to corruption identified through the risk assessment.

GUIDANCE​

Guidance for Disclosure 205-1
This disclosure can include a risk assessment focused on corruption or the inclusion of corruption as a risk factor in overall risk assessments.

The term ‘operation’ refers to a single location used by the organization for the production, storage and/or distribution of its goods and services, or for administrative purposes. Within a single operation, there can be multiple production lines, warehouses, or other activities. For example, a single factory can be used for multiple products or a single retail outlet can contain several different retail operations that are owned or managed by the organization.

Background
This disclosure measures the extent of the risk assessment’s implementation across an organization. Risk assessments can help to assess the potential for incidents of corruption within and related to the organization, and help the organization to design policies and procedures to combat corruption.

Disclosure 205-2 Communication and training about anti-corruption policies and procedures​

REQUIREMENTS​

The reporting organization shall report the following information:

  • a. Total number and percentage of governance body members that the organization’s anti-corruption policies and procedures have been communicated to, broken down by region.
  • b. Total number and percentage of employees that the organization’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region.
  • c. Total number and percentage of business partners that the organization’s anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region. Describe if the organization’s anti-corruption policies and procedures have been communicated to any other persons or organizations.
  • d. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region.
  • e. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region.

RECOMMENDATIONS​

  • 2.1 When compiling the information specified in Disclosure 205-2, the reporting organization should:
    • 2.1.1 draw from the information used for Disclosure 405-1 in GRI 405: Diversity and Equal Opportunity 2016 to identify:
    • 2.1.1.1 the governance bodies that exist within the organization, such as the board of directors, management committee, or similar body for non-corporate organizations;
    • 2.1.1.2 the total number of individuals and/or employees who comprise these governance bodies;
    • 2.1.1.3 the total number of employees in each employee category, excluding governance body members;
  • 2.1.2 estimate the total number of business partners.

GUIDANCE​

Guidance for Disclosure 205-2
In the context of this GRI Standard, the term ‘business partners’ includes, among others, suppliers, agents, lobbyists and other intermediaries, joint venture and consortia partners, governments, customers, and clients.

Background
Communication and training build the internal and external awareness and the necessary capacity to combat corruption.

Disclosure 205-3 Confirmed incidents of corruption and actions taken​

REQUIREMENTS​

The reporting organization shall report the following information:

  • a. Total number and nature of confirmed incidents of corruption.
  • b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.
  • c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.
  • d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

GUIDANCE​

Guidance for Disclosure 205-3
For stakeholders, there is an interest in both the occurrence of incidents and an organization’s response to the incidents. Public legal cases regarding corruption can include current public investigations, prosecutions, or closed cases.

Guidance for Disclosure 205-3-c
In the context of this GRI Standard, the term ‘business partners’ includes, among others, suppliers, agents, lobbyists and other intermediaries, joint venture and consortia partners, governments, customers, and clients.

Bibliography​

This section lists authoritative intergovernmental instruments and additional references used in developing this Standard.

Authoritative instruments:​

  1. Organisation for Economic Co-operation and Development (OECD) Convention, ‘Convention on Combating Bribery of Foreign Public Officials in International Business Transactions’, 1997.
  2. Organisation for Economic Co-operation and Development (OECD), Good Practice Guidance on Internal Controls, Ethics, and Compliance, 2010.
  3. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines for Multinational Enterprises, 2011.
  4. United Nations (UN) Convention, ‘Convention against Corruption’, 2003.

Additional references:​

  1. British Ministry of Justice, The Bribery Act 2010 Guidance, 2011.
  2. Criminal Division of the U.S. Department of Justice and Enforcement Division of the U.S. Security and Exchange Commission, A Resource 7uide to the U.S. Foreign Corrupt Practices Act, 2012.
  3. Transparency International, ‘Business Principles for Countering Bribery’, 2011.
  4. Transparency International, Corruption Perceptions Index, http://www.transparency.org/research/cpi/overview, accessed on 1 September 2016.
  5. United Nations Global Compact and Transparency International, Reporting Guidance on the 10th Principle Against Corruption, 2009.
  6. World Bank, Worldwide Governance Indicators (WGI), Control of Corruption, http://info.worldbank.org/governance/wgi/index.aspx#home, accessed on 1 September 2016.