In 2010, we bolstered our anti-corruption work, in line with a growing global focus on combating unclean business practices. In particular, increased enforcement of anti-corruption rules, not least by the U.S. Government of the U.S. Foreign Corrupt Practices Act, as well as the passing of a new anti-bribery act in the UK, gave cause for us to review our existing basic rules.
Our first action was to provide a set of anti-corruption guidelines, as part of the ISS Way. In November, we launched an anti-corruption policy, which brought new demands for compliance by country managers.
During 2010, Group Legal has reached out to all regional and country managers to explain the implications of the new policy, and to stress the importance of this in combination with our competition guidelines, which was updated in 2008. In 2009, 493 employees undertook this training. E-learning-based training and compliance programmes have been developed and launched. The training programme was compulsory for all top managers across the Group and we intend to roll out the training to other managers in the future.