Has the undertaking been convicted of corruption or bribery in the past five years?

A conviction for corruption is a fact, not an assessment

This is a factual question: has the company itself, or anyone on behalf of the company, been convicted of corruption or bribery in the past five years. No conviction simply means "no". A settlement or an ongoing investigation without a conviction is different from a conviction — do not automatically fill that in as "yes", but also not simply as "no" without checking what has actually been established. If you are in doubt about how to label a settlement or transaction, that is the moment not to confirm the answer and to ask the person who handled the file at the time, usually a lawyer or compliance officer.

This question often appears in the same section as the question of whether there is a policy against bribery and corruption is, and sometimes also next to the question about an internal whistleblower reporting channel. That makes sense: a client asking about convictions usually also wants to know if there is a preventive structure in place. Make sure the answers to those three questions are mutually consistent — a "no" on convictions next to a blank answer on policy stands out more quickly than when both are filled in consistently.

Where this comes from: the VSME base module

The VSME base module from EFRAG asks SMEs about convictions for corruption and bribery as part of the limited social and governance block that also appears in the free list. This is a factual question without explanation of cause or context — you can add that nuance yourself in a free text field if your client's portal allows it, but the base question itself only asks yes or no about the past five years.