Dear PK Jagadeesan,
Do you have model standing orders approved by the labour commissioner? If yes, then why do you need separate policy on the corruption? In case, if you do not have standing orders then I recommend you getting standing orders approved. Cases of misappropriation of funds can be handled under the provisions of standing orders.
Standing Orders have legal approval than a company policy. Hence this recommendation.
Thanks,
Dinesh Divekar