Does the undertaking have a policy against bribery and corruption?

Anti-bribery policy: documented in writing or not

The answer depends on what is written down, not on what happens in practice. Does the enterprise have a document — however brief — stating that bribery and corruption are not tolerated, and what employees should do if they suspect it? Then the answer is yes. If there is only a verbal agreement or a "we simply don't do that here"-culture without documentation, then the answer is no, even if the company is actually clean.

The question is often separate from, but is read in practice alongside whether the enterprise has been convicted of corruption or bribery in the past five years: a customer that includes these two questions in the same list wants to know whether the absence of convictions is based on policy or on chance. If the enterprise has no separate document but does have a general code of conduct containing an anti-bribery paragraph, that is also a valid yes — the form is flexible, the content must be comprehensive. If such a code is completely absent, then no is the honest answer; a commitment "we are working on it" is not a yes.

Where this comes from: VSME basic module, governance theme

The VSME basic module of EFRAG asks about the existence of policies on a limited number of governance themes, including bribery and corruption, as part of the minimum information that non-listed SMEs can report to their business relationships. It is a yes/no question about the existence of the policy, not an assessment of its content or effectiveness. Anyone who enters yes here without an underlying document runs the risk that a subsequent question — for example about an internal reporting channel for whistleblowers — will still ask for the supporting document that does not exist.