Effective anti-corruption and whistleblowing policies should define:
Who is covered by the policy, i.e. employees at all levels, external parties doing business with the issuer and those acting in an agency or fiduciary capacity on behalf of the issuer (e.g. agents, consultants and contractors).
What type of conduct is covered under the policy, including definitions of relevant aspects, i.e. what constitutes an advance, entertainment, gift, etc.
Who is responsible for the oversight and implementation of the policy, i.e. which committee / department / staff member.
How to report, i.e. which reporting channels are available to report possible misconduct in confidence.