Hilfreich für eigene Gedanken derjenigen Mitarbeiter, die in einem Unternehmen mit dem Thema Korruptionsvermeidung befasst sind: The Wolfsberg Guidance (Wolfsberg Paper 2011 issued by international private banks, together with Transparency International and the Basel Institute on Governance) provides the full component of a minimum anti-corruption and anti-bribery program. Such a program should include the following:
- The program should be developed by senior management and endorsed by the Board of Directors.
- A written policy and procedures which should address commercial and public corruption and bribery. It should include both actual bribery and offers of bribery.
- A clear delineation of the risks associated with public officials including a definition of ‘public officials’ which meets international standards.
- Internal communication of the full compliance program to all appropriate employees and to relevant third parties.
- Roles and responsibilities should be allocated to persons senior in the organization to ensure implementation.
- An independent unit within the company, such as compliance, legal or other department should be charged with providing day-to-day resources on the compliance program to all employees and third parties who may seek assistance.
- A firm commitment to the compliance program should be publicly communicated.
