questionnaire asks about our anti-bribery policy, what is a good answer

Four sub-questions under one heading

Anti-corruption policy usually does not appear in questionnaires as a single question, but as a cluster. Four variants come up repeatedly: does the enterprise have a policy against bribery and corruption, has the enterprise been convicted in the past five years, is there an internal reporting channel, and is there a procedure for conflicts of interest. These are four separate yes/no questions, each with their own supporting document, even if the client groups them under one heading such as "integrity" or "compliance". Enter them separately in your file, otherwise you will get stuck as soon as a client asks three of the four and leaves out the fourth.

For the first question, the supporting document is the policy document itself, signed or dated. If you do not have that, then "no" is the correct answer — an intention or a draft code of conduct is not a policy. What your client specifically expects from such a policy is set out on the page on what a client means by anti-corruption policy. The conviction question is factual: no conviction is "no", and you enter that without needing an explanation — see the explanation of the conviction question if you are in doubt whether a settlement or transaction falls under this. The reporting channel is often the same whistleblower arrangement that is also asked for separately; if you have already documented that for the whistleblower question, reuse the same supporting document here. The conflict of interest question is most often left unanswered in SME files, because there is rarely a separate procedure for it alongside the general integrity policy.

VSME basic module as the source of the classification

This division follows the basic module of the EFRAG VSME standard, which addresses anti-corruption as a separate theme alongside whistleblowers and conflicts of interest — which is why clients ask them separately even if they seem to go together in your view. The CSRD (Directive (EU) 2022/2464) is the reason larger clients collect this information systematically from their suppliers: they must report on it and you provide the building blocks. For the conviction question, client due diligence under the Law on the prevention of money laundering and the financing of terrorism also plays a role in the background, which explains why banks often phrase this question slightly differently than sustainability portals.