If my company has never had fines or convictions, do I just report “zero”?

When small and medium-sized enterprises (SMEs) start preparing sustainability reports, a common question is: what if we’ve never had any convictions or fines for corruption or bribery?

The answer is simple: yes, you should report “zero” rather than leave the disclosure blank.

1. What the standard says

Under the VSME Basic Module, Disclosure B11 requires companies to report:

• The number of convictions for corruption or bribery in the reporting year.
• The total amount of fines for such offences.

If there were none, you must still make a statement confirming this.

2. Why not leave it blank?

An empty disclosure can create confusion: did the company overlook the requirement, or are there truly no cases?

By explicitly reporting “zero”, you make it clear that you are compliant and that your record is clean — reassuring banks, customers, and other stakeholders.

3. How to phrase it

Keep it simple and factual. For example:

“In 2024, [Company Name] recorded zero convictions and no fines for violations of anti-corruption or anti-bribery laws.”

Or:

“[Company Name] confirms that no convictions or fines occurred during 2024.”

Either format is acceptable as long as it is explicit.

4. Adding context (optional)

While not required under the Basic Module, some SMEs choose to mention their anti-corruption practices (e.g. staff training, whistleblowing channels, supplier codes of conduct). This can help show that the clean record is supported by active measures. Learn more about anti-corruption disclosures for CSRD.

5. Practical tip

Maintain a simple “nil disclosure log” each year. Record either:

• The number of cases and total fines, or
• A note of “zero convictions/fines” if none occurred.

This makes it easier to copy the information straight into your sustainability report and keeps your reporting consistent year to year.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law requiring large companies (and eventually some medium ones) to report on their environmental, social, and governance impacts. Smaller suppliers are not directly in scope but may be asked for CSRD-style data.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified framework to help SMEs disclose sustainability information, aligned with CSRD but voluntary.
• Basic Module — The minimum set of disclosures under VSME, covering essential environment, social, and governance data.
• Anti-corruption disclosure (B11) — The requirement to report the number of convictions and total fines for corruption or bribery in the reporting year.