Governance policies a sustainability report asks for: anti-corruption, whistleblowing, health and safety

Why policies come up in every questionnaire

Customer questionnaires, bank ESG forms, EcoVadis and the EU voluntary standard (VSME) all ask whether you have written policies on certain topics. A policy shows that management has decided how the company behaves, who is responsible and how people can raise problems. The VSME asks which sustainability topics your policies cover, whether they are public and whether they have targets, and how many convictions and fines for corruption and bribery you had.

Anti-corruption and bribery

An anti-corruption policy says that the company does not offer, pay or accept bribes, directly or through agents. It sets rules for gifts, hospitality and donations, requires conflicts of interest to be declared, explains how to report suspicions, and names the consequences of breaking it. In the UK, the Bribery Act 2010 makes a company liable for failing to prevent bribery unless it had adequate procedures, so a policy with training and records is the core of its defence.

Whistleblowing

Under the EU Whistleblower Directive, Directive (EU) 2019/1937, private employers with 50 or more workers must set up internal reporting channels. Reports must be acknowledged within seven days and followed up with feedback within three months; the reporter’s identity is kept confidential, and retaliation is forbidden. Employers with 50 to 249 workers may share the resources for receiving and investigating reports. Each country has its own law, such as the Dutch Whistleblowers Protection Act, the German Whistleblower Protection Act, Spain’s Law 2/2023 and Italy’s Legislative Decree 24/2023.

Health and safety

Every employer in the EU must assess the risks to workers’ health and safety and take preventive measures, under the Framework Directive 89/391/EEC and national law. In the UK, employers with five or more employees must have a written health and safety policy. A good policy states management’s commitment, names who is responsible for what, and describes the arrangements: risk assessments, training, first aid, accident reporting and how often it is reviewed.

The other policies you will be asked about

Depending on your sector and customers, expect questions about these as well:

• A code of conduct covering human rights, including child labour, forced labour and discrimination.
• An environmental or sustainability policy.
• A supplier code of conduct.
• Data protection under the GDPR.
• Equal opportunities, diversity and anti-harassment.

What every policy needs

A policy that only exists on paper does not convince anyone. Each should have a purpose and scope, the people responsible, how it is put into practice and communicated, how concerns are raised, approval by management with a date, and a review date. Keep evidence that it is used: training records, the reports received and what was done with them.

Doing it in Greener Ahead

Greener Ahead does not write policies for you. Sustainability reporting in Greener Ahead prepares a VSME report that records which policies you have, whether they are public, your workforce and health and safety figures, and convictions and fines for corruption, with the document behind each answer. It costs €995 per year with unlimited users, and you can try it free for 14 days without a card. Check the pricing page for current details.

Policies at a glance

Which policies are legal duties and which are asked for by customers.

Check each policy against this list

Before you send it to a customer.

• It has a purpose, a scope and named responsibilities.
• Management approved it, with a date.
• Employees know it exists and where to find it.
• It explains how to raise a concern.
• It has a review date, and you keep evidence that it is used.