Are companies expected to “adopt” the Business Principles?
The Business Principles are not designed to be “adopted” en bloc or “signed up” to. They have been created as a good practice model and not necessarily to be adopted word-for-word. Companies’ needs will vary according to risk, size, sector and geographic reach. In developing or amending their anti-bribery programmes, companies should take account of the specific nature of their activities and tailor their policies and programmes to address specific risks and vulnerabilities. Although we do not expect companies to “adopt” the Business Principles, we hope that they will state that they have “applied” the Business Principles or used them as a reference point in developing or reviewing their own policies and programmes.