Article
Anti-corruption, harassment and discrimination pack: simple small actions for a Belgian SME
In brief
A very "Belgian SME / EcoVadis" selection: simple, credible, documentable and communicable actions without building a bureaucratic machine. It was built for an ESGIM client — a Walloon building-services (HVAC/electrical) installer, size XS — and transfers as-is to any Belgian SME. Starting point: EcoVadis assesses the management system through Policy-Actions-Results; documents must be formalised, recent, pre-existing and demonstrate practices actually implemented (reference: EcoVadis Help Center). For a small structure, simple documents suffice: a signed commitment letter, action plans, evidence of concrete actions, reporting elements.
Which ten small actions prevent corruption risk?
| Simple action | How to set it up | Possible EcoVadis evidence |
|---|---|---|
| Gifts / invitations register | Table: date, third party, nature, estimated value, accepted/refused, management approval | Anonymised register or PDF extract + short procedure |
| "Symbolic gifts only" rule | Simple limit: no money, no significant personal gift, nothing during a tender | Signed internal note + communication to teams |
| Anti-corruption clause (purchase orders / GTC) | Standard sentence: no bribery, conflicts of interest or hidden commissions; termination right | Sample purchase order, GTC, contract |
| Annual conflict-of-interest declaration | Buyers, sales, management and project leads confirm any personal links | Signed form or register |
| Two-level validation of sensitive suppliers | New strategic supplier or intermediary: management approval + VAT/registry/reputation check | Completed "new supplier" checklist |
| 20-minute mini-awareness session | Toolbox: gifts, tenders, suspicious payments, conflicts of interest | Attendance sheet + 3-page material |
| Internal reporting address | ethics@ or hr@ for reporting fraud or unethical behaviour | Procedure + screenshot of the communicated address |
| Targeted accounting control | Once a year: gift expenses, restaurants, commissions, unusual expense reports | Internal control report, however brief |
| Supplier message | One page "our ethical expectations" sent to key suppliers | Email + recipient list |
| Anti-corruption point in onboarding | Five lines in the induction path | Signed onboarding checklist |
Useful references: the Belgian anti-corruption guide (prevention, awareness, clear rules), the French Anti-Corruption Agency's SME guide (code of conduct, partner evaluation, alert mechanism, simple accounting controls) and the ICC on proportionate third-party due diligence.
The 5 most profitable: gifts register, supplier clause, annual mini-training with attendance, new-supplier checklist, communicated reporting channel. Note: in Belgium the internal whistleblowing channel is mandatory from 50 workers; below that, voluntary (except specific sectors) — but good ESG evidence.
Which ten small actions prevent harassment and discrimination?
| Simple action | How to set it up | Possible EcoVadis evidence |
|---|---|---|
| Name / recall the contact person | Display who to contact: HR, management, confidential counsellor, external psychosocial prevention advisor | Poster, intranet, email to staff |
| Annual "zero tolerance" communication | Short management message: no moral or sexual harassment, no discrimination, no retaliation | Signed email + archived PDF |
| Procedure in the work regulations | How to report, to whom, confidentiality, no retaliation | Work regulations / annex / HR note |
| Manager mini-training (30 min) | Recognising an inappropriate joke, exclusion, hiring discrimination | Attendance sheet + material |
| Non-discriminatory recruitment checklist | Standardised criteria: skills, experience, certificates, availability — never age, origin, gender, health, family situation | Job-advert template + interview grid |
| Non-discrimination clause in job adverts | "Selection based on skills, equal opportunities" | Examples of published adverts |
| Exit interview with dedicated question | Ask leavers whether they observed harassment or a toxic climate | Anonymised form or annual summary |
| Annual social-climate micro-survey | 5 anonymous questions: respect, inclusion, confidence to report | Aggregated results + decided actions |
| "Respect at work" toolbox (15 min) | Concrete examples of acceptable / unacceptable behaviour | Attendance sheet + toolbox sheet |
| Anonymised incident register | Report type, handling, measure, closure | Anonymised table + annual summary |
Belgian framework: the FPS Employment requires employers to prevent psychosocial risks (violence, moral and sexual harassment); the confidential counsellor is mandatory from 50 workers, optional below except on collective request; workers can turn to the confidential counsellor or the psychosocial prevention advisor. Unia insists: prevention is not just sanctioning after the fact — equal treatment belongs in recruitment, promotion, training, pay and working relations.
The 5 most profitable: annual communication signed by management, displayed reporting procedure, clearly identified contact person, mini-training or toolbox, recruitment checklist.
What does the evidence pack look like as one PDF?
For an SME, assemble a single file titled for instance "Prevention measures — Ethics, anti-corruption, respect at work and non-discrimination — 2026": (1) signed management commitment, (2) gift/invitation/conflict-of-interest rules, (3) register — template + extract, (4) supplier anti-corruption clause, (5) completed new-supplier checklist, (6) reporting procedure, (7) staff communication, (8) internal harassment/discrimination note, (9) contact persons and psychosocial procedure, (10) training/toolbox with attendance sheet, (11) simple indicators: people trained, reports, confirmed incidents, corrective actions.
This is exactly the kind of evidence that shows EcoVadis not an intention but operational implementation: communication, training, register, clause, procedure, control, reporting.
Key takeaways
- Twenty small actions, each with its evidence: the effort counts in hours, the credibility in years.
- The 5 most profitable anti-corruption proofs: gifts register, supplier clause, mini-training, third-party checklist, reporting channel.
- Belgian thresholds: whistleblowing channel and confidential counsellor mandatory from 50 workers — voluntary but valuable below.
- A single 10-15 page PDF assembles everything into proof of operational implementation.
- Simple indicators (trained, reports, corrective actions) turn actions into Results.