GUIDELINES FOR THE PREPARATION OF AN
FOR PUBLIC INSTITUTIONS
The Directorate of Preventive Services
This is a brief guideline that can be used by organizations to develop their
Anti-Corruption Policy. It highlights the key components that should be
included in the Anti -Corruption Policy.
Institutions can customize the guidelines to suit their needs.
This will be a brief introduction to the Policy document, preferably by
the Board or the Chief Executive recognizing corruption risk in an
organization and acknowledging that corruption can occur
2. POLICY STATEMENT
Outline the plan of action to guide decisions and actions in fighting
corruption in the institution. The statement should confirm that the
responsibility of addressing corruption rests with management, staff,
and stakeholders. It should also indicate the commitment of the
management to deal with corruption decisively. It shall also emphasize
the importance of the policy document.
3. LEGISLATIVE AND ADMINSTRATIVE REQUIREMENTS/CONTEXT
List the legal instruments and institutional policies that are applicable
(e.g. The Anti Corruption and Economic Crimes Act, 2003, Public
Officer Ethics Act, 2003), Public Procurement and Disposal Act 2005,
and the Government Financial Management Act, 2004, the
4. SCOPE /APPLICABILITY
Identify the persons to be bound by the policy. It may be important to
indicate that the policy applies to both management and staff of the
5. DEFINITION OF CORRUPTION
It is necessary that all staff members in the institution understand what is
deemed as corruption and their responsibilities for prevention and
detection of corruption at the workplace. It is important to refer to
corruption offences under the Anti Corruption and Economic Crimes
Act of 2003.
The possibilities of corruption are many but an understanding of what is
corruption may be better understood by providing some examples
from the institution. For example, conflict of interest is a corruption
offence. The policy document could explain what it entails e.g
“conflict of interest arises from situations where you as an
employee/chief executive of the organization have a private interest
that could potentially influence or appear to influence, the impartial
and objective performance of your official duties. Private interests
include any advantage to you or your family, close relatives, friends
and persons or organizations with whom you have business or political
relations. Such clarification is necessary so as to avoid ambiguity in
determining what encompasses corruption. (See IEC materials
provided by KACC)
6. A BREAKDOWN OF CORRUPTION RISK AREAS AND CORRUPT
PRACTICES IN THE INSTITUTION
All functional areas in the institution are potential risk areas. They
• Financial Management Systems and Procedures
• Information, Communication and Technology Systems (ICT)
• Human Resources and other areas
• Records management among others
List all the functional areas in the institution and specify the risks in these
7. STRUCTURES TO FIGHT CORRUPTION
Outline the structures to be put in place to prevent, detect, investigate
and punish corrupt officers.
8. COMPOSITION OF THE CORRUPTION PREVENTION COMMITTEE/
State the office and not the name of the officer)
The Chief Finance Officer (Member)
The Chief Legal (Member)
Chief Internal Auditor (Member)
Chief Procurement Officer (Member)
Integrity Assurance Officer (Secretary)
Membership of the Committee will vary from institution to institution
9. MANDATE AND OPERATIONS OF THE CORRUPTION PREVENTION
State the role and functions of the Corruption Prevention Committee
within the institution
Setting priorities in the prevention of corruption within the organization
Planning and coordinating corruption prevention strategies
Integrating all corruption prevention initiatives in their organizations.
Receiving and reviewing reports on corruption prevention initiatives and
recommend appropriate action.
Receiving and taking action on corruption reports made by staff and
other stakeholders. Evidence of concrete measures taken must be
made available and any referrals to other agencies well documented.
Spearheading anti-corruption campaigns within their jurisdiction.
Monitoring and evaluating the impact of corruption prevention initiatives
Preparing and submitting quarterly progress reports to the Performance
Contract Steering Committee.
10. INTERNAL AUDIT REVIEWS
The management could mention the crucial role of the Internal Audit
Department. Internal Audit plays a crucial role in prevention and
detection of corruption within an institution. It provides an
institutionalized mechanism for supervision, control and review of
operational systems within the institution. It also plays an important role
in assessing the nature and extent of any fraud and corruption risk.
11. HOW TO REPORT CORRUPTION INTERNALLY AND EXTERNALLY
Cover issues of how to make a disclosure of corrupt practices within
the institution, the use of avenues for reporting such as , corruption
reporting boxes, hotlines, emails, websites etc and to whom (the
office), such disclosures should be made to.
In addition, state how corruption can also be reported to the Kenya
Anti Corruption Commission. (See IEC materials provided by KACC)
12. HANDLING OF CORRUPTION CASES
Provide a statement on how corruption cases will be dealt with- fairly,
promptly, expeditiously, within the law etc.
Corruption cases deliberated upon and supported by cogent
evidence or reasonable suspicion that a corruption offence has
occurred or about to occur should be reported to the Kenya Anti
Corruption Commission and other law enforcement agencies for
13. PROTECTION OF WHISTLEBLOWERS
It is important to protect the identity of persons making corruption
disclosures and to ensure that information that might identify the
person making the disclosures is not released and if there is any need
to release such information; this will be discussed firstly with the person.
Provide a statement to emphasize protection of persons making
corruption disclosures against any reprisals or detrimental action in
relation to the disclosures.
14. DISCIPLINARY MEASURES
Make provision referring to the disciplinary procedures for breaches of
the provisions of this policy.
The management should commit itself to sensitization and training of
staff on matters of ethics and integrity
16. MANAGEMENT/IMPLEMENTATION AUTHORITY
Apportion responsibility for implementation of the policy to the
management, an office or a committee as management may deem
Indicate when the policy will be subjected to review. This may be
determined by the management e.g the policy document shall be
reviewed at such intervals as the Management may determine.
18. EFFECTIVE DATE
The date that the policy comes into effect.
Issued this day of 2007
Signed by the CEO