Anti Bribery & Corruption

Anti-bribery and corruption obligations for private companies typically focus on preventing, detecting, and addressing bribery and other corrupt acts by employees or associated persons. These obligations may include requirements to implement internal policies, provide training, establish reporting and investigation procedures, and disclose relevant information as required by law or applicable ESG standards.

Yes, this policy area covers situations where a private company or individual offers or attempts to offer a bribe to a public official, whether domestic or foreign, if such conduct is regulated by law. It does not cover obligations that apply only to public officials or government entities accepting bribes, nor does it address money laundering or witness tampering.

Corruption is prevalent around the globe and can be engaged in by private individuals, public officials and businesses. There can be domestic bribery in the form of private to public bribery/corruption or private to private bribery/corruption. There can also be bribery that involves attempts to corrupt foreign officials. It can take different guises, from the giving and taking of bribes to conflicts of interest and undue influence. 

There are many different definitions of bribery and corruption, but it is generally accepted that, whichever definition is employed, there are common elements: the act of bribery or corruption involves a person in an appointed position or entrusted with power who acts voluntarily in breach or abuse of that trust in exchange for a private gain. 

Acting corruptly may include acting with improper purpose personally. Examples of this include making or providing false or misleading statements, withholding information or influencing another person.A bribe is generally regarded as “a gift, consideration or advantage” to a person as an inducement to, or reward for, or otherwise on account of, any person performing an act in relation to his or her office, employment, position or business.

The United Nations Convention against Corruption (UNCAC) remains the only global, legally binding anti-corruption instrument. This was drafted and negotiated in Vienna, Austria in 2002-2003 and was then adopted by the United Nations General Assembly on 31 October 2003. The Convention entered into force on 14 December 2005 and currently includes 140 signatories and 192 parties (as of 25 September 2025).

This adoption represented a significant milestone in the shared international commitment to fighting corruption. This Convention takes a comprehensive approach to anti-corruption measures, placing importance on preventive measures, criminalization and law enforcement, international cooperation, as well as asset recovery.

Yes, ESRS G1, Business Conduct. In addition, ESRS G2, General Disclosures, would also need to be consulted for disclosure requirements related to anti-bribery and anti-corruption.

The objective of ESRS G1 is to specify disclosure requirements aimed at helping users of the company’s sustainability statements to understand the company’s strategy, approach, processes and procedures in relation to how it conducts its business. As part of this, business ethics and corporate culture, including anti-corruption and anti-bribery and the protection of whistleblowers, is specifically addressed.

Information regarding the existence of, or plans for future implementation of, corporate anti-bribery and anti-corruption policies are to be disclosed. Company policies should address prevention, detection, and response to any corrupt activities. In addition, information is to be provided regarding how a company plans to provide protection to whistleblowers.