"The International Corporate Governance Network (ICGN) has published best practice guidelines on political contributions (the Guidelines). The Guidelines adopt a multi-jurisdictional approach, outlining a global policy for political donations for companies….
The Guidelines’ policy framework, akin to the Bribery Act’s adequate procedures defence, consists of four guiding principles: legitimacy, transparency, accountability and responsibility. The Guidelines focus on ensuring that any political activities undertaken are in the long term interests of the company and are governed in a way that manages potential risks robustly. The Guidelines set out the following procedures to assist companies with minimising the risk of engaging in political activity:
•Communication – company policy and processes in relation to political donations should be communicated clearly by company management both throughout the organisation (including company agents and external representatives when representing company interests) and publicly (with disclosures relating to the timing, amount and intent of political spending easily found on a company’s website)
•Training – appropriate and regular training should be given to all company representatives who engage in corporate political activity
•Risk management system – companies should establish robust internal controls and reporting processes to monitor compliance with company policies on corporate political activity. Material breaches of the policies should be brought to the immediate attention of the board
•Board responsibility – the board should approve explicitly the company’s policies with regard to political donations and have oversight of all political activity
•Client and employee background – companies should be transparent about the issue of hiring employees, including board directors, or dealing with individuals who have, or have had, influential roles in politics
•Shareholders’ approval – shareholders should be able to vote on a company’s political donations policy."