Chapter VII.2: Anti-bribery control systems

Develop and adopt adequate internal controls, ethics and compliance programmes or measures for preventing and detecting bribery, developed on the basis of a risk assessment addressing the individual circumstances of an enterprise, in particular the bribery risks facing the enterprise (such as its geographical and industrial sector of operation). These internal controls, ethics and compliance programmes or measures should include a system of financial and accounting procedures, including a system of internal controls, reasonably designed to ensure the maintenance of fair and accurate books, records, and accounts, to ensure that they cannot be used for the purpose of bribing or hiding bribery. Such individual circumstances and bribery risks should be regularly monitored and re-assessed as necessary to ensure the enterprise‟s internal controls, ethics and compliance programme or measures are adapted and continue to be effective, and to mitigate the risk of enterprises becoming complicit in bribery, bribe solicitation and extortion.

All Cases  Closed Cases   Overdue Cases (more than 12 months)
Title sort up sort down Issue Host Country(s) Lead NCP Date submitted NCP Decision Current status sort up sort down Duration sort up sort down Positive outcome
Michelin V Tamil Nadu Land Rights Federation, Thervoy Grama Makkal Munnerta Nala Sanga, CCFD-Terre Solidaire, Confédération Générale du Travail (CGT), Association Sherpa

Land rights; destruction of livelihoods; deforestation


France NCP




Closed on 27/09/2013
63 weeks and 4 days
Liberian International Ship and Corporate Registry V ITF

Breach of UN arms embargo; money laundering






Closed on 01/10/2002
47 weeks and 5 days