Anti-corruption 'adequate procedures': policy acknowledgements and declarations

Section 17A of the MACC Act makes commercial organisations liable for corruption by associated persons unless they have adequate procedures — evidence matters.

Why now

  • Corporate liability under MACC Act Section 17A has been in force since 2020.
  • Auditors and boards ask for proof that staff and vendors acknowledged policies.
  • Gifts and conflict-of-interest declarations are often on paper.

Who it's for

  • Integrity and compliance officers
  • HR
  • Procurement

Typical problems

  • Incomplete records of policy acknowledgements.
  • Paper gift declarations.
  • Vendor integrity pledges not tracked.

What we deliver

  • Annual policy acknowledgement campaign with Acrobat Sign
  • Gift and conflict-of-interest declaration workflow
  • Vendor integrity pledge in onboarding

Where to start

Quick winAll-staff anti-bribery acknowledgement with a completion dashboard.

How to measure success

  • % staff acknowledged
  • % vendors with signed integrity pledge
  • Declarations logged per quarter