Dear member,
Rather than designing the "Policy on Anti-Corruption Practices," I recommend you rename it as "Policy on Ethical Practices." Non-compliance with this policy is corruption. However, corruption manifests in various forms, not solely as bribe-taking. Therefore, it is crucial to understand the nature of your business, identify the scope of corruption, and implement measures to curb corrupt practices.
Designing a policy on ethical practices is a crucial step, yet insufficient. It is essential to define what constitutes "misconduct" when corrupt practices are uncovered. If corrupt practices come to light but misconduct is not clearly defined in the standing orders, disciplinary action cannot be taken.
Lastly, although your message is concise, you seem to have blurred the distinction between policy and SOP. The initial step should be to clarify this distinction. While a policy on ethical practices is appropriate, an SOP is not.
Thanks,
Dinesh Divekar