公司对反腐败合规性的评估

©OECD2025. This work is published under the responsibility of the Secretary-General of the OECD.The opinions expressed and argumentsemployed herein do not necessarily reflect the official views of the Member countries of the OECD. This document and any map included herein are without prejudice to the status of or sovereignty over any territory, tothe delimitationof international frontiers and boundaries and to the name of any territory, city or area. Cover design: ©kitka / iStock /Getty ImagesPlus Attribution4.0 International (CCBY4.0) This work is made available under the Creative Commons Attribution4.0 International licence. By using this work, you accept to bebound by the terms of this licence (https://creativecommons.org/licenses/by/4.0/). Attribution–youmust cite the work. Translations–you must cite the original work, identify changes to the original and add the following text:In the event of anydiscrepancy between the original work and the translation, only the text of original work should be considered valid. Adaptations–you must cite the original work and add the following text:This is an adaptation of an original work by the OECD.The opinions expressed and arguments employed in this adaptation should not be reported asrepresenting the official views of theOECD or of its Member countries. Third-party material–the licence does not apply to third-party material in the work. If using such material, you are responsible forobtaining permission from the third party and for any claims of infringement. You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your Foreword The landscape of anti-corruption efforts has shifted in recent years; once led by governments and their lawenforcement agencies, the private sector has become an increasingly essential actor. Companies aroundthe globe have invested in the development of anti-corruption compliance programmes andrecognisethattheseinvestments must,in effect,prevent corruption.The importance of assessing complianceprogrammes’ effectiveness has long beenemphasisedby international standards. In its Good PracticeGuidanceon Internal Controls,Ethics,and Compliance,the OECD Recommendation for FurtherCombating Bribery of Foreign Public Officials in International Business Transactionsoutlines a roadmapfor assessments by guidingcompanieson how to establish effective measures for preventing and detectingforeign bribery and corruption(OECD, 2021[1]).Yet assessing the effectiveness of compliance programmeshas proven challenging and requires that companies set clear objectives, measure progress and impact,and foster a culture of integrity. This paper aims to support companies in their assessment efforts by taking stock of the methodologiesand tools that they use to evaluate and enhance the effectiveness oftheir anti-corruption complianceprogrammes. It outlines the factors that motivate companies’ assessment efforts, addresses the resourcesand capacities required to conduct assessments, and considers the tools that can be leveraged to monitorprogress overtime. Drawing on desk research and data collected by the OECD and the Basel Institute on Governance, thispaper contributes to promoting strong anti-corruption norms and standards within the public and privatesectors. Itis one component of a two-part projectdeveloped with the support of the US State Departmentand within the framework of theGalvanizing the Private Sectorinitiative. The project’s second component, entitled Governments’ Assessments of Corporate Anti-CorruptionCompliance, complements this paper by mapping out existing guidance from public authorities on anti-corruption compliance criteria and assessment methodologies and highlighting areas where governmentscan learn from private sector practices(OECD, 2025[2]). It also sets out companies’ recommendations togovernments on how to better communicate theirexpectations about corporate anti-corruption complianceprogrammes, assessment criteria, methodologies and tools. Acknowledgements The OECDwould like tothank allthecompanies,businessassociations, government, civil societyandinternational organisations thatshared their insightsfor the purposes ofthis report.Special thanks go tothemembers of the Anti-CorruptionLeadership Hub,a forum of Chief Compliance Officers or equivalentfrom major,multinational enterprises convened by the OECD, the companieswho agreed toparticipate inthe consultation conducted by the Basel Institute on Governance in cooperation with the OECD, as wellas otherparticipants in the OECD expert meeting on the margins of theOECD Global Anti-Corruption andIntegrity Forumin March2024.This report would not have been possible without the support of theUnitedStates governmentas part of theGPSinitiative. This reportwas prepared by Anaïs Michel, Legal Analyst in the Anti-Corruption Division of the OECDDirectorate for Financial and Enterprise Affairs, under the direction of Elodie Be