Anti-corruption - Global Reporting Initiative

GRI Additional Public Comment Period for G4 Thematic Revisions
OVERVIEW
INTRODUCTION
GRI is issuing, for public comment, proposed thematic revisions to the topics of Anti-corruption and
Greenhouse gas (GHG) emissions. The documents will be available for comment from 14 August to 12
November 2012. During the Additional Public Comment Period for G4 Thematic Revisions, any interested
party can provide feedback on one or both topics.
This Additional Public Comment Period is complementary to the Second G4 Public Comment Period, which
features an exposure draft of the G4 Guidelines. The proposed thematic revisions are built upon the content
and structure featured in the G4 Exposure Draft.
This document outlines the G4 project development process and the proposed thematic revisions to the
topics of Anti-corruption and GHG emissions. The document also explains how you can submit feedback
during this Public Comment Period (PCP).
BACKGROUND
In September 2010, GRI’s Board of Directors (the Board) approved plans to start developing the next
generation of its Reporting Guidelines (G4), and set out the following objectives:
• to offer guidance in a user-friendly way, so that new reporters can easily understand and use the
Guidelines
• to improve the technical quality of the Guidelines’ content in order to eliminate ambiguities and
differing interpretations – for the benefit of reporters and information users alike
• to harmonize as much as possible with other internationally-accepted standards
• to improve guidance on identifying ‘material’ issues – from different stakeholders’ perspectives – to
be included in sustainability reports
• to offer guidance on how to link the sustainability reporting process to the preparation of an
integrated report, aligned with the guidance to be developed by the International Integrated
Reporting Council (IIRC)
In May 2011, GRI began informal external consultations 1 to understand what was considered to be needed in
order to achieve the objectives stated above. Formally, all GRI Reporting Framework development must
follow a Due Process 2 , which ensures that all efforts are made to involve and consider the interests of all GRI’s
stakeholders, including those from business, civil society, financial markets, consultancy services, labor and
academia.
The first PCP for G4 (August to November 2011) was the start of the formal consultation process. It attracted
around 2300 participants, 1832 of whom provided a submission via an online survey 3 . Based on the G4
1 Informal consultations included a Primer Survey, a Call for Topics and a call to register for the G4 Public Comment Periods. Visit the G4 development
process page on GRI’s website to download a copy of these documents.
2 Download a copy of GRI’s Due Process document from the Due Process Reporting Framework page on GRI’s website
3 Download a report on the findings from the First G4 Public Comment Period on GRI’s website
i

objectives set by the Board, the results of this consultation, and previous informal consultations, Working
Groups were created to develop revised content for the current Guidelines. An exposure draft of the next
generation of the guidelines (G4) was issued for public comment from 25 June to 25 September 2012.
Working Groups were also created to develop revised content on the following topics:
• Anti-corruption
• Greenhouse Gas (GHG) Emissions
As defined in the GRI Due Process, Working Groups are formed by the Secretariat, under the direction of the
Board and in consultation with the Technical Advisory Committee. Selection criteria include expertise,
stakeholder diversity, and availability. Proposed revisions to the text of the Guidelines or Protocols are drafted
by the Working Groups as outlined under Overarching Due Process Principles. The Technical Advisory
Committee is responsible for reviewing proposals put forward by the Working Groups.
PROPOSED REVISIONS FOR COMMENT
The proposed thematic revisions are summarized below. These revisions are built upon the content and
structure featured in the G4 Exposure Draft.
Anti-corruption
The Anti-corruption Working Group proposed a number of changes to existing disclosures for anti-corruption,
and proposed to locate certain new and revised disclosures under a new Ethics section. Updated definitions
and references, and changes to existing terminology, were included to make disclosures clearer and more
focused; and to align G4 with best practice in anti-corruption disclosure.
The proposed revisions include:
• Strategy, Profile and Governance
o New disclosures under a new section ‘e. Ethics’
• Disclosure on Management Approach
o New disclosures and guidance (Anti-corruption Aspect, Society Category)
• Indicators
o Specific edits to Indicators SO2, SO3, and SO4 (Anti-corruption Aspect, Society Category)
o Specific edits to Indicator SO6 (Public Policy Aspect, Society Category)
Greenhouse Gas (GHG) Emissions
The GHG Emissions Working Group proposed a number of changes mainly covering disclosures under the
Aspects of Energy and Emissions (formerly Emissions, Effluents, and Waste) in the Environmental Category.
Disclosures in other areas of the Guidelines relevant to reporting GHG emissions are also included. The
proposed revisions intend to support reporting and align with the GHG Protocol, jointly released by the World
Resources Institute and the World Business Council for Sustainable Development, and the ISO 14064 standard
produced by the International Organisation for Standardisation.
The proposed GHG Emissions Indicators are fully aligned with the GHG Protocol’s grouping of emissions into
three subsets (Scopes 1, 2, and 3), as well as the ISO 14064 grouping. Energy Indicators have been modified to
align with the GHG Emissions Indicators for more streamlined reporting. Intensity Indicators were added for
both energy and GHG emissions.
Compilation points for each Indicator have been made consistent across Indicators and other reporting
frameworks, and allow for more detailed reporting to assist with the comparability of data.
ii

The proposed revisions include:
• Disclosure on Management Approach
o New disclosures and guidance for the Energy and Emissions Aspect (Environmental Category)
• Indicators
o Edits to Indicator EC2 (Economic Performance Aspect, Economic Category)
o Edits to Indicators EN3 – EN7 and Indicators EN16 – EN20 (Energy and Emissions Aspects,
Environmental Category)
o New indicators under the Energy and Emissions Aspects, Environmental Category
YOUR OPPORTUNITY TO COMMENT
The Additional Public Comment Period for G4 Thematic Revisions is open from 14 August to 12 November
2012.
GRI invites you to provide:
1. General Comments in response to specific questions from GRI about proposed content
2. Editorial comments on the text
The specific questions (for General Comments) follow after this Overview. Editorial comments on the text in
the thematic revisions are limited to changes proposed by the Working Groups. This text is marked up in black
to indicate it can be commented on. Text in grey is unchanged from the current Guidelines and is presented
for contextual purposes only. These parts are not for comment.
How to submit your comments
The GRI Consultation Platform is a secure website where you can submit your comments. You will need to
register your details and choose a password before you begin. This password and your email address will
allow you to enter the site to add to your comments over time. This means you can save your feedback, and
return later, until you have said all you want to say. Your comments will remain private until you are ready to
submit them to GRI.
Once registered, choose the G4 Thematic Revisions consultation on the homepage.
Comments are especially helpful if they include a rationale and, where appropriate, make specific suggestions
for any proposed changes to wording. Any comments submitted without a rationale and/or that do not relate
to the section where the text is placed (i.e., that are out of context), will not be considered by GRI.
The GRI Consultation Platform is the easiest and preferred method for you to provide your comments.
Written or email submissions are not ideal, but are accepted. If you choose to provide your comments in this
format, you must be as precise as possible in indicating which content your comments relate to. Submissions
must be received at GRI’s offices by 12 November 2012.
Submissions in languages other than English should be sent via email or by post. The GRI Consultation
Platform supports English only.
Email submissions can be sent to: G4@globalreporting.org
Postal submissions can be sent to: G4 Additional Public Comment Period – G4 Thematic Revisions, GRI
Secretariat, Postbus 10039, 1001 EA Amsterdam, The Netherlands
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GRI Additional Public Comment Period for G4 Thematic Revisions
Questions for General Comment – Anti-corruption
INTRODUCTION
GRI invites the public to provide:
1. General Comments in response to specific questions from GRI about proposed content
None of the questions listed below are mandatory. Please answer those questions that allow you to provide
the most useful feedback to GRI.
Responses should be submitted in English via the GRI Consultation Platform. Follow G4 Thematic Revisions >
General Comments section. See the Overview document for submissions in other languages.
QUESTIONS FOR GENERAL COMMENT
ANTI-CORRUPTION QUESTIONS
1. Do you consider the disclosures proposed by the Anti-corruption Working Group appropriate and/or
complete?
o Yes
o No, please clarify:________________
2. Please choose one option:
The proposed Ethics disclosures (DI New 1, DI New 2 and DI 57) should be located
o within the Governance disclosures in the Strategy, Profile and Governance section
o as a standalone subsection in the Strategy, Profile and Governance section
3. Do you have other general comments related to the disclosures proposed by the Anti-corruption Working
Group?
4. External references
GRI invites suggestions for the names of recent and useful documents that can assist organizations in either
understanding more about this topic’s presence in the Guidelines, or help them to manage and report on
topics.
GRI has strict criteria for assessing if a reference should be listed in its Guidelines. Please refer to these before
suggesting a document. Please include a hyperlink to the document if publicly available.
Public Comment Period open from 14 August – 12 November 2012
iv

• The organization provides publicly-available information about the development process of this
reference
• The reference was developed using a collaborative, representative, robust, and transparent process;
or developed in an inter-governmental setting
• The reference is generally applicable
• The reference is applicable to all organizations regardless of size or sector
• The reference is available in English
• The reference is available free of charge
• The reference is current and in use
Public Comment Period open from 14 August – 12 November 2012
v

G4 Development
Additional Public Comment Period for G4 Thematic
Revisions
Anti-corruption
Open for Comment 14 August – 12 November, 2012

[This document contains only those sections of the G4 Exposure Draft that have been reviewed by the
Working Group]
THE REPORTING GUIDELINES
Part 2: Disclosure items
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 2

1. Strategy, Profile and Governance
[...]
d. Governance
[…]
HIGHEST GOVERNANCE BODY’S ROLE IN EVALUATING ECONOMIC, ENVIRONMENTAL, AND SOCIAL
PERFORMANCE
[Disclosure] DI 54
Report the frequency of the highest governance body’s review of economic, environmental, and social
goals and performance.
[Disclosure] DI 55
Describe the process for escalating complaints to the highest governance body.
[Disclosure] DI 56
Report the nature and number of complaints that are communicated to the highest governance body.
1
2
3
4
[Disclosure] DI 57
Describe processes to encourage the internal and external reporting of unlawful and unethical behavior
and to promote ethical behavior. Describe whistleblowing processes, use of hotlines and other similar
mechanisms and whether or not these are independent of the organization.
[See new proposal for DI 57 under e. Ethics]
[…]
5
6
7
8
9
10
11
12
13
14
15
16
e. Ethics
[Disclosure] DI New 1
Describe the organization’s values, principles, codes of conduct, codes of ethics, standards and norms of
behavior.
Report the status of their implementation, and related initiatives to promote ethical behavior.
[Disclosure] DI New 2
Describe internal and external mechanisms for seeking advice on ethical and lawful behavior, such as
helplines or advicelines, including:
• Who is assigned the overall responsibility for the mechanisms for seeking advice
• Whether the mechanisms for seeking advice are independent of the organization
• Whether and how employees and business partners are informed of the mechanisms for
seeking advice
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 3

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23
24
25
26
27
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30
31
32
33
34
35
36
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39
40
41
42
43
44
45
46
47
• The availability of the mechanisms for seeking advice (e.g., number of hours per day, days per
week)
• The accessibility of the mechanisms for seeking advice to employees and business partners,
including availability in local languages
• Whether questions are treated confidentially
• Whether the mechanisms for seeking advice allow for anonymous questions
Report the number of questions received during the reporting period through the organization’s
mechanisms for seeking advice. Of these questions, report the percentage that were answered during
the reporting period.
[Disclosure] DI 57
Describe internal and external mechanisms for reporting allegations of unethical or unlawful behavior,
such as escalation through line management, whistleblowing mechanisms or hotlines, including:
• Who is assigned the overall responsibility for the reporting mechanisms
• Whether the reporting mechanisms are independent of the organization
• Whether and how employees and business partners are informed of the reporting mechanisms
• The availability of the reporting mechanisms (e.g., number of hours per day, days per week)
• The accessibility of the reporting mechanisms to employees and business partners, including
availability in local languages
• Whether training on the reporting mechanisms is provided to employees and business partners
• Whether allegations are treated confidentially
• Whether the reporting mechanisms allow for anonymous allegations
• Whether the organization has a non-retaliation policy
• The process through which allegations are investigated
Report the total number of allegations made through reporting mechanisms, broken down by type of
misconduct. Of these allegations, report the percentage that were:
• Addressed during the reporting period
• Resolved during the reporting period
• Found to be unsubstantiated
Report the total number of allegations filed prior to the reporting period that were resolved during the
reporting period.
[Guidance] Definitions
48
MECHANISMS FOR REPORTING ALLEGATIONS OF UNETHICAL OR UNLAWFUL BEHAVIOR
49
50
51
52
53
54
Systems and processes through which an individual can report allegations of unethical or unlawful
behavior. Individuals may include the organization’s employees, business partners or the general public.
Unethical and unlawful behavior may include wrongdoing such as civil offences (including negligence,
breach of contract, breach of administrative law), corruption, crime, dishonesty, disrespect, human
rights violations, health, safety and environmental threats, illegal activities, intentionally misleading
behavior, maladministration or substantial waste of public money, and miscarriages of justice.
[...]
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 4

2. Disclosure on Management Approach
[See pages 42 – 46 in the G4 Exposure Draft]
[...]
4. Disclosure on Management Approach and Indicators per category:
economic, environmental and social
[...]
Society
[...]
Disclosure on Management Approach
For each material Society Aspect, provide the Disclosure on Management Approach items outlined in
section ‘2. Disclosure on Management Approach’. Provide the additional Disclosure items listed below
for each material Aspect:
• Local Communities
[...]
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
• Anti-cCorruption
[Disclosure]
Report whether the organization has a publicly stated commitment to zero tolerance of
corruption.
Report which forms of corruption are covered in the anti-corruption policy.
Report whether and which stakeholders were involved or consulted in formulating and
implementing the anti-corruption policy.
Report how the anti-corruption policy is communicated to the organization’s governance body
members, employees, and business partners.
Report processes to prevent, detect, investigate, respond to and remediate forms of corruption.
Report processes for identifying and managing conflicts of interest that employees or persons
related to the organization may have.
Report processes for assessing business partners for risks related to corruption, and which types
of business partners were assessed.
Report policy and procedures in place to ensure that charitable donations and sponsorships
(financial and in-kind) that are made to other organizations are not used as a disguised form of
bribery.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 5

72
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80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
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100
101
102
103
Report the criteria and processes used to identify which governance body members, employees,
and business partners receive training on anti-corruption.
Report the approach to providing training and capacity building on the organization’s anticorruption
policy and procedures to business partners, and which types of business partners
receive training.
Report whether and how the effectiveness of the anti-corruption training for governance body
members, employees, and business partners is evaluated.
Report the organization’s collective action activities to combat corruption, including the main
commitments of collective action initiatives in which the organization participates.
[Guidance]
For guidance on forms of corruption, see the definition of corruption.
Conflicts of interest for the highest governance body are covered in the Governance disclosure
‘DI 43’.
Recipients of charitable donations and sponsorships (financial and in-kind) may include but are
not limited to not-for profit organizations, religious organizations, private organizations and
events.
When disclosing collective action activities, provide:
• The strategy towards collective action activities
• A list of collective action initiatives in which the organization participates
• A description of the main commitments of these initiatives
Definitions
COLLECTIVE ACTION TO COMBAT CORRUPTION
For the disclosure on the organization’s collective action activities to combat corruption,
collective action is understood as voluntary engagement with initiatives and stakeholders to
improve the broader operating environment and culture to combat corruption. It can include
proactive collaboration with peers, the public sector, trade unions and civil society organizations
with the aim of combating corruption.
References
• Organisation for Economic Co-operation and Development (OECD), Good Practice Guidance
on Internal Controls, Ethics, and Compliance, 2010.
• United Nations Global Compact (UNGC) and Transparency International, Reporting
Guidance on the 10th Principle Against Corruption, 2009.
• Public Policy
[...]
• Anti-Competitive Behavior
• Compliance
• Screening and Assessment
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 6

• Remediation
[...]
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 7

[This document contains only those sections of the G4 Exposure Draft that have been reviewed by the
Working Group]
THE REPORTING GUIDELINES
Part 3: Indicator Protocols
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 8

[...]
Society Indicators
[...]
104
ASPECT: ANTI-CORRUPTION
105
106
CORE SO2
Percentage and total number of business units analyzed
operations assessed for risks related to corruption
[Standard Disclosure]
Compilation
107
108
109
110
111
112
113
114
115
116
117
Report the total number and percentage of business units analyzedoperations assessed for risks related
to corruption.
Report:
• The criteria used in the risk assessment
• Whether risks for the organization and risks for external stakeholders were considered in the
risk assessment
• Whether the risk assessment was a formal risk assessment focused on corruption or corruption
was included as a risk factor in an overall risk assessment
• Whether an external party conducted or contributed to the risk assessment
Report the percentage and total number of operations identified as having high risk of incidents of
corruption. Describe these risks of incidents of corruption identified through the risk assessment.
[Guidance]
Relevance
118
119
120
121
122
123
124
125
126
Corrupt practices involving governance body members, employees or business partners have negative
impacts on the organization and society. Efforts to manage reputational these impacts and risks arising
from corrupt practices by employees or business partners require a system that has supporting
procedures in place. This measure Indicator identifies two specific actions for ensuring the effective
deployment of the organization’s policyies and procedures by its own governance body members,
employees and its intermediaries or business partners. Risk assessments analysis is an important and
necessary management approach that helps 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.
Methodology for data collection
127
128
129
Identify business units analyzed operations assessed for organizational risks related to corruption during
the reporting period. This refers to either a formal risk assessment focused on corruption or the
inclusion of corruption as a risk factor in overall risk assessments.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 9

130
131
132
133
134
135
136
137
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139
Identify the criteria used in the risk assessment. Risk assessment criteria may include but are not limited
to location, activity and sector.
Identify whether risks for the organization and risks for external stakeholders were considered in the
risk assessment. Risks for the organization may include but are not limited to reputational risks, financial
impacts, and legal and civil actions. Risks for external stakeholders may include but are not limited to
increased costs of products and services and conversion of public wealth to private and personal
property.
Identify whether the risk assessment was a formal risk assessment focused on corruption or whether
corruption was included as a risk factor in an overall risk assessment.
Identify whether an external party conducted or contributed to the risk assessment.
Definitions
None.
Documentation
140
Potential information sources include monitoring reports, risk registers or risk management systems.
References
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142
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144
145
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153
• OECD Convention on Combating Bribery of Foreign Public Officials in International Business
Transactions, 1997.
• OECD Guidelines for Multinational Enterprises, Revision 2000.
• Inter-American Convention Against Corruption, 1996.
• United Nations Convention Against Corruption, 2003.
• Business Principles for Countering Bribery, 2003.
• Organisation for Economic Co-operation and Development (OECD), OECD Guidelines for
Multinational Enterprises, 2011.
• Organisation for Economic Co-operation and Development (OECD) Convention, 'Convention on
Combating Bribery of Foreign Public Officials in International Business Transactions', 1997.
• Transparency International, Corruption Perceptions Index, updated annually.
• Transparency International, Business Principles for Countering Bribery, 2009.
• United Nations (UN) Convention, ‘Convention against Corruption', 2003.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 10

154
ASPECT: ANTI-CORRUPTION
155
156
157
CORE SO3
Percentage of employees trained in organization’s anti-corruption
policies and proceduresInformation and training on anticorruption
policy and procedures
[Standard Disclosure]
Compilation
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
Report, separately, the percentage of both management and non-management employees who have
received anti-corruption training during the reporting period.
Report the total number and percentage of governance body members and employees informed of the
organization’s anti-corruption policy and procedures, broken down by employee category.
Report the total number and percentage of business partners informed of the organization’s anticorruption
policy and procedures, broken down by type of business partner. Where it will provide
appropriate context, report the percentage of turnover or purchasing volume that these business
partners account for.
Report the total number and percentage of governance body members and employees that have
received training on anti-corruption, broken down by employee category.
Report the total number and percentage of governance body members and employees identified as
having high risk of incidents of corruption that have received training on anti-corruption, broken down
by employee category.
For those governance body members and employees identified as having high risk of incidents of
corruption and that have received training on anti-corruption, report whether the training was:
• specialized anti-corruption training or more general training which included anti-corruption
• tailored to each employee category
• web-based or in-person
Report the content of the training(s).
[Guidance]
Relevance
177
178
179
180
181
182
183
Efforts to manage risks arising from corrupt practices by employees or business partners require a
system that has supporting procedures in place. Training is an important element of such a system as it
builds internal awareness and capacity necessary to prevent incidents of corruption. Communication
and training build the internal and external awareness and the capacity necessary to combat corruption.
This measure Indicator reveals the proportion of the organization’s governance body members,
employees and business partners that can reasonably be assumed to be aware of the anti-corruption
issues.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 11

Methodology for data collection
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
Identify the existence and scope of the organization’s anti-corruption policies and procedures, and
whether these contain processes for the training of employees in relation generally to the organization's
operating environment and specifically in relation to its own procedures.
Identify the total number and percentage of governance body members and employees informed of the
organization’s anti-corruption policy and procedures, broken down by employee category.
Identify the total number and percentage of business partners informed of the organization’s anticorruption
policy and procedure, broken down by type of business partner.
Identify the total number and percentage of governance body members and employees that have
received training on anti-corruption, broken down by employee category.
Identify the total number and percentage of governance body members and employees identified as
having high risk of incidents of corruption that have received training on anti-corruption, broken down
by employee category.
For those governance body members and employees identified as having high risk of incidents of
corruption and that have received training on anti-corruption, identify whether the training was:
• specialized anti-corruption training or more general training which included anti-corruption
• tailored to each employee category
• web-based or in-person
Identify the types content of anti-corruption the training undertaken. This may include but is not limited
to anti-corruption, anti-bribery, and/or code of conduct training.
Identify the total number of employees, distinguishing between management and non-management
employees, using the data from LA1.
Calculate the percentage of employees that have undertaken training in accordance with the policies
identified above.
Definitions
207
208
209
210
211
212
213
214
215
None.
GOVERNANCE BODIES
The committees or boards responsible for the strategic guidance of the organization, the effective
monitoring of management, and the accountability of management to the broader organization and its
stakeholders.
EMPLOYEE CATEGORY
Breakdown of employees by level (e.g., highest governance bodies, senior management, middle
management) and function (e.g., technical, administrative, production). Derived from an organization’s
own human resources system.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 12

Documentation
216
Potential information sources include training records and internal audit risk assessments.
References
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• OECD Convention on Combating Bribery of Foreign Public Officials in International Business
Transactions, 1997.
• OECD Guidelines for Multinational Enterprises, Revision 2000.
• Inter-American Convention Against Corruption, 1996.
• United Nations Convention Against Corruption, 2003.
• Business Principles for Countering Bribery, 2003.
• Organisation for Economic Co-operation and Development (OECD) Convention, 'Convention on
Combating Bribery of Foreign Public Officials in International Business Transactions', 1997.
• Organisation for Economic Co-operation and Development (OECD), OECD Guidelines for
Multinational Enterprises, 2011.
• Transparency International, Business Principles for Countering Bribery, 2009.
• United Nations (UN) Convention, ‘Convention against Corruption', 2003.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 13

229
ASPECT: ANTI-CORRUPTION
230
231
CORE SO4
Actions taken in response to incidentsConfirmed incidents of
corruption and actions taken
[Standard Disclosure]
Compilation
232
233
234
235
236
237
238
239
240
241
Report total number of confirmed incidents of corruption. Describe the confirmed incidents of
corruption.
and Report actions taken in response to theseconfirmed incidents, including but not limited to:
• the total number of confirmed incidents in which employees were dismissed or disciplined for
corruption; and
• the total number of confirmed incidents when contracts with business partners were
terminated or not renewed due to violations related to corruption.
• actions to improve the anti-corruption program
Report any concluded legal cases regarding corrupt practicescorruption brought against the organization
or its employees during the reporting period and the outcomes of such cases.
[Guidance]
Relevance
242
243
244
245
246
247
248
249
Corruption can be a significant risk to an organization’s reputation and business. It is broadly linked to
contributing toadverse 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 increasingly expected by the marketplace, international norms, and stakeholders
to demonstrate their adherence to integrity, governance, and good business practices. This Indicator
demonstrates specific actions taken to limit exposure to sources of corruption and reduce the risks of
new instances of corruption. For stakeholders, there is an interest in both the occurrence of incidents,
but also how the organization chooses to respond.
Methodology for data collection
250
251
252
253
254
255
256
257
258
Identify the total number of confirmed incidents of corruption.
‘Incident of corruption’ refers to each individual case of corruption.
A description of the confirmed incidents of corruption may include but is not limited to:
• The nature of the incident
• The stakeholders involved
• The impacts on affected stakeholders
• Any resulting criminal and civil sanctions
Identify the total number of confirmed incidents in which employees were dismissed or disciplined for
corruption.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 14

259
260
261
262
263
264
Identify the total number of confirmed incidents when contracts with business partners were
terminated or not renewed due to violations related to corruption.
Identify actions to improve the anti-corruption program.
Identify concluded legal cases regarding corruption brought against the organization or its employees
during the reporting period, and the outcomes of such cases. Information on conditions, outcomes
handed down is to be disclosed.
Definitions
265
266
267
268
None.
CONFIRMED INCIDENTS OF CORRUPTION
Incidents of corruption that have been found to be substantiated. This does not include incidents of
corruption that are still under investigation in the reporting period.
Documentation
269
270
271
Potential information sources include legal department records of cases brought against the
organization, its employees, or business partners, or contractors; minutes of the proceedings of internal
disciplinary hearings; and contracts with business partners.
References
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• United Nations Convention Against Corruption, 2003.
• OECD Convention on Combating Bribery of Foreign Public Officials in International Business
Transactions, 1997.
• Inter-American Convention Against Corruption, 1996.
• OECD Guidelines for Multinational Enterprises, Revision 2000.
• Anti-Corruption Instruments and the OECD Guidelines for Multinational Enterprises, 2003.
• Business Principles for Countering Bribery, 2003.
• Organisation for Economic Co-operation and Development (OECD), OECD Guidelines for
Multinational Enterprises, 2011.
• Organisation for Economic Co-operation and Development (OECD) Convention, 'Convention on
Combating Bribery of Foreign Public Officials in International Business Transactions', 1997.
• Transparency International, Business Principles for Countering Bribery, 2009.
• United Nations (UN) Convention, ‘Convention against Corruption', 2003.
• United Nations Global Compact (UNGC) and Transparency International, Reporting Guidance on
the 10th Principle Against Corruption, 2009.
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[...]
ASPECT: PUBLIC POLICY
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ADD SO6
Total value of financial and in-kindpolitical contributions to
political parties, politicians, and related institutions, by country
[Standard Disclosure]
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Compilation
Report, by country, the total monetary value of financial and in-kind political contributions made
directly and indirectly by the organizationduring the reporting period to political parties, politicians, and
related institutions. This information should be broken down by country.
Report the estimation methodologies used for in-kind political contributions, if applicable.
[Guidance]
Relevance
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The purposes of this Indicator areis to reflect the scale of the reporters’ engagement in political
fundingan organization’s support for political causes, and to ensure integrity and transparency in its
political dealings and relationships with the organization.
Direct or indirect contributions to political causes can present risks of corruption as they may be used
for undue influence or to corrupt the political process. Many countries have legislation that sets limits on
official expenditure by parties and political candidates for campaigning purposes, and contributions may
be made improperly to circumvent such legislation. This can include channeling contributions indirectly
through intermediaries, lobbyists, or organizations linked to political causes.
Methodology for data collection
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Identify in which countries financial and in-kind political contributions have been made directly or
indirectly by the organization.to political parties, politicians, and related institutions. For those countries
where:
• The organization has major operations and/or sales;
• The organization holds a significant share of the market in comparison to other organizations; or
• The sums contributed are significant compared to the total amount contributed globally.
Calculate these monetaryfinancial political contributions in accordance with national accounting rules
(where these exist).
The value of in-kind political contributions is to be estimated. Estimation methodologies need to be
stated.
Definitions
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POLITICAL CONTRIBUTIONS
Any financial or in-kind support given directly or indirectly to political parties, their elected
representatives, or persons seeking political office. Financial cContributions canmay include donations,
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loans, sponsorships, retainers, or the purchase of tickets for fundraising events. In-kind contributions
may include, advertising, use of facilities, design and printing, donation of equipment, retainers or the
provision of jobs for elected politicians or candidates for office, etc.
RELATED INSTITUTIONS
Any bodies established with the primary purpose of arranging official or unofficial funding support for
political parties, their elected representatives, or persons seeking political office. This definition also
includes think-tanks, policy organs, trade associations, and other support organizations that are linked
to the creation of support for political parties, their representatives, or candidates for office.
INDIRECT POLITICAL CONTRIBUTIONS
Any financial or in-kind support made either through intermediary organizations such as lobbyists or
political action committees or through organizations such as think tanks or trade associations that are
linked to the creation of support for political parties, their representatives, candidates for office or
engagement on public policy.
Documentation
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Potential information sources of information include the accounting records of external payments and
in-kind contributions and public disclosure statements.
References
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• OECD Guidelines for Multinational Enterprises, Revision 2000.
• Organisation for Economic Co-operation and Development (OECD), OECD Guidelines for
Multinational Enterprises, 2011.
[...]
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 17

[This document contains only those sections of the G4 Exposure Draft that have been reviewed by the
Working Group]
THE REPORTING GUIDELINES
Part 5: Glossary
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 18

[...]
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BUSINESS PARTNER
Business partners include, among others, suppliers, agents, lobbyists and other intermediaries, joint
venture and consortia partners, franchises, licensees, governments, customers, and clients. In GRI’s
Framework, suppliers include brokers, consultants, contractors, distributors, home workers,
independent contractors, primary producers, sub-contractors and wholesalers.
[...]
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CONFLICT OF INTEREST
Situation where an individual is confronted with choosing between the duties and demands of different
roles, whether professional or private.
[...]
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CORRUPTION
Corruption is ‘the abuse of entrusted power for private gain’ 1 and can be instigated by individuals or
organizationsin the public or private sector. It is interpreted here to include such corrupt In GRI’s
Framework, corruption includes practices such as bribery, facilitation payments, fraud, extortion,
collusion, conflict of interest, and money laundering. In this context, itIt also includes an offer or receipt
of any gift, loan, fee, reward, or other advantage to or from any person as an inducement to do
something that is dishonest, illegal, or a breach of trust in the conduct of the enterprise’s business. 2 This
may include gifts other than moneycash or in-kind benefits, such as free goods, gifts, and holidays, or
special personal services provided for the purpose of, or liable to result in, an improper advantage or
that may result in moral pressure to receive such an advantage.
[The revised definition of ‘Corruption’ is based on the definition of ‘Corruption’ found in the G3.1
Guidelines, on page 2 of the Indicator Protocols Set Society (SO)]
[...]
1 Transparency International
2 These definitions are based on ‘Business Principles for Countering Bribery’ which have been developed through a project
managed by Transparency International.
Additional Public Comment Period for G4 Thematic Revisions – Anti-corruption 19