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Herbert Smith Freehills business ethics and anti-bribery policy survey

24 March 2017 | Australia
Legal Briefings – By Jacqueline Wootton and Anita Thompson


We recently conducted a survey of the business ethics, codes of conduct and anti-bribery policies published by the ASX Top 150 companies.

Codes of conduct and anti-bribery policies set the framework for a company’s approach to anti-corruption compliance. Although only one component of an effective compliance system, they outline expectations and provide a baseline to guide employees through what can be complex issues to address in practice.

Overall, the results of the survey indicated a solid commitment to integrity in business dealings amongst the ASX Top 150:

  • the overwhelming majority of companies publish a code of conduct on their website;
  • in almost all cases the code of conduct addresses ethics, integrity and/or bribery;
  • well over half of the companies surveyed have corporate values or mission statements that reinforce the importance of ethics and integrity; and
  • over 35% of companies show a ‘tone from the top’ by embedding an explicit statement of support from senior personnel (the Chairman, CEO or other senior executives) in their codes of conduct or anti-bribery policy.

Energy, Mining, Resources & Materials companies demonstrated the strongest commitment of all sectors towards addressing ethics and integrity in their published materials. Our sector-specific results showed that:

  • all surveyed companies in the sector publish a code of conduct on their website and 68% have updated their code in the past two years;
  • those codes of conduct tended to be longer and more comprehensive than the average for the ASX Top 150 overall;
  • in all cases the code of conduct expressly addresses ethics or anti-bribery/ corruption issues; and
  • 47% of companies in the sector publish an anti-bribery policy on their website (compared to the overall average of 31%).

We also found that Energy, Mining, Resources & Materials companies displayed a strong tendency to support reporting behaviour, with 95% of companies encouraging reporting of any issues and 55% including a reporting “hotline” in their code of conduct and/ or anti-bribery policy.

For more information about our survey, and our overall findings, please contact Grant Marjoribanks or Jacqueline Wootton.

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