Dear member,
Rather than designing the "Policy on Anti-Corruption Practices", I recommend you rename it as "Policy on Ethical Practices". The non-compliance with this policy is corruption.
However, corruption is always in many forms. It need not be in the form of bribe-taking. Therefore, one needs to understand the nature of your business, identify the scope of corruption and measures to curb the corrupt practices.
Designing a policy on ethical practices is not sufficient. You need to define what constitutes "misconduct" when corrupt practices are revealed. By chance, the corrupt practices are revealed, and if the misconduct is not defined in the standing orders, then you cannot initiate disciplinary action.
Lastly, though your post is short or even the shortest, you appear to have confused between policy and SOP. The first step will be to remove this doubt. You can have a policy on ethical practices but not the SOP!
Thanks,
Dinesh Divekar