经合组织《反贿赂公约》第四阶段后续报告：《公约》和相关法律文书的执行情况

Implementing the Conventionand Related Legal Instruments Disclaimers This work was approved and declassified by the Working Group on Bribery in International Business Transactions on 23 June 2026. This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation ofinternational frontiers and boundaries and to the name of any territory, city or area. Photo credits:© Epitavi / iStock / Getty Images Plus. © OECD 2026. Attribution 4.0 International (CC BY 4.0) This work is made available under the Creative Commons Attribution 4.0 International licence. By using this work, you accept to be bound by the terms of this licence(https://creativecommons.org/licenses/by/4.0/). Attribution–you must cite the work. Translations–you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and thetranslation, 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 employedin this adaptation should not be reported as representing the official views of the OECD 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 for obtaining permission from the third party andfor any claims of infringement. Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitration Rules 2012. The seat of arbitrationshall be Paris (France). The number of arbitrators shall be one. Table of contents Summary and conclusionsSummary of findingsConclusions of the Working Group on Bribery 415 Annex A. Follow-Up Report by Türkiye16 Notes65 Summary and conclusions Summary of findings1 1.In April 2026, Türkiye submitted its Phase 4 Two-Year Written Follow-up Report to the OECDWorking Group on Bribery in International Business Transactions (Working Group). This report describesTürkiye’s efforts to implement the 71 recommendations and to address the follow-up issues identifiedduring its Phase 4 evaluation in June 2024. In sum, Türkiye has fully implemented 10 recommendations,partially implemented 12 and not implemented 49. 2.The Working Group is again dismayed at the large number of recommendations that are notimplemented, which includes the top priority items identified by the Working Group during Türkiye’sprevious follow-up reportin June 2025. First, despite the Working Group’s urging since 2007, there is nosign that Türkiye will enact whistleblower protection legislation in the foreseeable future. Second, theTurkish government has still not developed or introduced draft legislative amendments to impose liabilityon corporations absent conviction of natural persons or for accounting offences. Third, there remains nosystem in place to promptly disseminate allegations of foreign bribery to prosecutors for investigation andprosecution. 3.Also, of great concern is Türkiye’s failureto demonstrate to the Working Group that it has undertakensufficient efforts to investigate and prosecute actual foreign bribery allegations. The Phase 4 Report foundthat Türkiye had not investigated almost two-thirds of the 23 known allegations of foreign bribery committedby Turkish individuals and/or companies. Since then, Türkiye has not opened any new investigations orprosecutions, including into three additional allegations that have come to light. As in Phase 4, thereremains no convictions for foreign bribery. Furthermore, still no prosecutorial unit has been officiallydesignated with primary responsibility for foreign bribery enforcement, which is an issue that the WorkingGroup has also identified as a top priority. 4.By contrast, Türkiye is to be commended for its efforts in addressing several lesser issues. Forexample, Türkiye conducted various training and awareness-raising activities aimed at helping its officialsprevent, detect, and sanction foreign bribery. Additionally, the Ministry of Foreign Affairs reviewed itspolicies and procedures for identifying and reporting foreign bribery and issued a new guide for its staff atheadquarters and diplomatic missions, although the reporting procedures outlined therein still leave ampleroom for improvement. Türkiye’s June 2025National Anti-Money Laundering and Countering TerrorismFinancing Risk Assessment specifically considered the risk of money laundering predicated on foreignbribery. Regarding detection of foreign bribery 5.Recommendation 1(a)–Not implemented: Türkiye has not developed a government-widenational strategywhich encompasses prevention, detection, and enforcement. Türkiye’s follow-up reportonlyrefers to awareness-raising activities described under recommendation 1(b).Such efforts arecommendable.Howev