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What is an Organisational Anti-Corruption Plan (OACP)?

What is an Organisational Anti-Corruption Plan (OACP)?

An organisational anti-corruption plan (OACP) is a roadmap for an organisation to address the governance, corruption, and integrity risks faced in its business in a clear and structured manner. It describes the initiatives and actions that have been put in place to mitigate these risks by charting a strategy to effectively prevent, detect and respond to them.

Any OACP should have the following fundamental objectives:

  • To make the initiatives and actions the basis for the organisation’s integrity and anti-corruption practice, and for the inculcation of ethical business culture within the organisation;
  • To help the organisation prevent, identify and respond to corruption, and comply with related anti-corruption laws as well as apply best practices; and
  • To assure management, employees, customers, associates, and other stakeholders that the organisation is putting in place and implementing integrity vetting for high-risk activities and positions for the prevention of corruption in its operations.

While a typical OACP uses the results of a Corruption Risk Assessment (CRA) exercise as its main component, there are other elements that are critical contributors. At VisionEthics, we utilise a customised 7-step approach to produce a functional OACP. This methodology was devised based on our experience working with multiple clients from various industries.

It seamlessly integrates the critical elements within the OACP framework to produce a plan which is both robust and practical. Most importantly, it gives the organisation a true indicator of its effectiveness in addressing its corruption risk.


An outline of our 7-step approach appears below:

VisionEthics' organisational anti-corruption plan (OACP) methodology shown in a flow chart

Key Highlights

  • Performing a comprehensive 360o risk assessment using multiple sources such as CRA, Audit and media reports, and in-person interviews
  • Prioritising risks to efficiently address those which are immediate and have the highest impact and likelihood of occurring. This helps establish context on the level of integrity for the organisation
  • Aligning identified risks to the organisation’s Vision, Mission, and Strategic Goals to produce a customised, purpose-built Corporate Governance Framework
  • Embedding related elements of the National Anti-Corruption Plan (NACP) into the plan to demonstrate compliance with the national agenda
  • Monitoring, evaluation, and review of the plan to ensure it remains valid and effective to meet the challenges of a changing business environment
  • Benchmarking the effectiveness of the plan using clearly defined indicators throughout its life cycle
  • Viewed as an evolving document that guides and shapes the daily actions and integrity practice of the organisation’s employees

What is included in an organisational anti-corruption plan?

A typical OACP should include:

  • A detailed anti-corruption action plan which typically covers a 3 to 5 year period
  • Clearly defined parameters for each initiative including:
    • Ownership – the department(s) entrusted to undertake the initiative. These department(s) will directly benefit from the successful implementation of the initiative
    • Timelines – determined by taking into account factors such as the urgency of the initiative, readiness to implement, and availability of resources
  • Roles and responsibilities of critical stakeholders within the organisation including:
    • Board of Directors;
    • Board Audit or Governance Committee;
    • Senior Management;
    • Integrity Unit;
    • Operational Departments
  • A reporting strategy outlining the interaction between the various stakeholders involved, frequency of reporting, and deliverables
  • Mid-term review to gauge the effectiveness of the plan against current corruption risk and provide the opportunity for future re-assessment of the plan

Critical success factors of an organisational anti-corruption plan

For any OACP to successfully realise its objectives, there are several critical factors which are necessary:

  • Commitment from the Top: The organisation’s Board of Directors and Senior Management must set the right tone by providing direction, endorsement, and leadership by example at all times to employees. This is turn will promote and embed a workplace culture that practices Integrity and Good Governance
  • Monitoring, Evaluation, and Mid-term Review: Taking action to transform the OACP is a “Living Document” which is regularly monitored, evaluated, and reviewed to ensure that it remains current, valid, and effective in the organisation’s continuous fight against corruption risk, both current and new
  • Communications and Accountability: Implementing training to raise awareness among all stakeholders of the plan’s objective and their individual responsibility, and ensuring that this knowledge is well understood and practised
  • IGU’s Independence: Prioritising the independence of the Integrity Unit so that it can operate with the necessary resources and autonomy to ensure the OACP is fairly implemented and enforced
  • Independent Review: An independent review will help in auditing the OACP initiatives and verify that the intended indicators and objectives are being followed and achieved


When planned properly with incorporations of the relevant components, an OACP will provide the necessary defenses against your organisation’s corruption risks. In doing so, you will be strongly instilling a culture of integrity in your employees. In the long run, this will ultimately benefit your employees and your business.


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Teh Chau Chin
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Datin Radhika Nandrajog
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Mohd Rezaidi Mohd Ishak
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Chak Tze Chin
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