Corruption is not a problem that only affects public institutions or large companies. Unfortunately, even small firms with a small team and a modest budget can find themselves put in delicate situations: from pressures in dealing with the authorities to unofficial demands from suppliers or customers. In such a context, a clearly formulated anti-corruption policy tailored to the size and needs of a small or medium-sized enterprise can make the difference between stability and vulnerability.

Adopting such a policy is not just a statement of principle, but also a practical measure. Firstly, it helps minimise legal risks. A firm with clear and transparent rules more easily avoids legal problems, fines and, in some cases, even the loss of licences or authorisations. Secondly, large companies and institutions prefer to work with trustworthy, ethical partners that implement a consistent anti-corruption policy. Moreover, such a commitment to integrity has direct effects on the team - people value a fair and predictable working environment and this contributes to employee loyalty and a solid reputation in the market.

Beyond the external aspects, such a policy also has an essential internal role. In the absence of clear rules, important decisions may be made on questionable criteria and any deviations may go unnoticed. Establishing an ethical framework helps better internal governance and objective decision-making.

How to build an anti-corruption policy in an SME?

The process does not need to be complicated, but it is important that it is coherent and rigorous. Start with a management commitment. It's not just good intentions, but a formal decision that needs to be put on the record - either in a written decision or a clear internal memo. It is essential that this message is taken and clearly communicated within the organisation: corruption is not tolerated under any circumstances.

The next step is risk assessment. At this stage, analyse where problems may arise: in dealings with local authorities, in the procurement process, in liaising with intermediaries or in situations where unusual payments are made. Each vulnerability needs to be identified and understood in terms of how serious the impact might be and how likely it is to occur.

Based on these findings, the actual policy is drafted. The document does not need to be long or complicated, but adapted to the realities of the organisation. What is essential is that it contains clear rules that are easy for all employees to understand and apply.

Once finalised, the policy must be put into practice. This means reaching out to all those concerned - employees, collaborators, partners. This can be done through short trainings, internal publicity, or inclusion in commercial contracts. The important thing is that everyone knows what is allowed and what is not.

The policy is not a static document. It needs to be monitored and, if necessary, adjusted. A co-ordinator - who may be the CEO - is in charge of overseeing the application of the rules and ensuring that, at least once a year, the policy is reviewed. If unforeseen situations or incidents arise, the review can take place even earlier.

What should an effective anti-corruption policy contain?

For small businesses, simplicity is key. The document should be easy to navigate and put into practice. A functional structure could include the following elements:

Aim and basic principles - It reaffirms zero tolerance for corruption, a commitment to respect the law and a willingness to conduct business with transparency and integrity.

Scope - It makes it clear that the policy applies to everyone: from management, to employees, collaborators, suppliers and other partners.

Key definitions - To avoid confusion, it is important to define terms such as bribery, facilitation payments, conflict of interest, sponsorship or undue advantage.

Concrete bans - It stipulates that bribes are not offered or accepted in any form. Informal payments, although common in practice, are prohibited. Political contributions are also excluded, unless clearly regulated and transparent.

Rules on gifts and hospitality - Only those token gifts or occasional invitations that do not arouse suspicion are allowed. Any gesture that is frequent, of high value or in an inappropriate context should be avoided.

Conflicts of interest - All employees are asked to declare any personal or financial relationships that could influence their professional decisions.

Donations and sponsorship - They can only be made if they are justified and do not conceal an indirect advantage for the firm. Everything must be documented and transparent.

Responsibilities - It makes it clear who is in charge of enforcing the policy, and every employee is obliged to comply with it and report any breaches.

Reporting channels - Anonymous reporting of irregularities is encouraged through accessible means (dedicated email, suggestion box, telephone number).

Sanctions - Breaches of the policy can have consequences, ranging from warnings to dismissal or referral to the relevant authorities.

An anti-corruption policy does not require major investments or unnecessary red tape. It is a realistic measure that helps small businesses stay competitive, respected and protected. With simple and clear rules, such a policy can protect the company against risks and can be a guarantee of reliability in the eyes of partners and employees.