The measures you take will depend on the size of your organisation and the extent of your risks. You should seek independent advice as to the appropriateness of any programme. Appropriate measures may include:
undertaking an assessment of the likely risks of bribery arising from your business operations
establishing clear policies about the payment or receipt of bribes by an employee, agent, contractor or other person associated with your organisation and the consequences for breaching those obligations
including an anti-corruption training and guidance programme for staff
ensuring someone has responsibility for monitoring compliance with relevant laws
establishing whistle-blowing procedures for staff to report corruption
undertaking due diligence on any proposed new business relationship, both in relation to the party and the country
including anti corruption policies in contract and procurement agreements with agents, partners and sub-contractors and requiring them to implement similar policies and procedures.