Elements to Establishing and Effective Anti-Bribery & Corruption Programme
Best practice offers a number of basic principles to consider when developing your Anti-Bribery & Corruption programme. Following these basic steps will allow you to better understand the level and type of risks your business is exposed to and identify the most appropriate measures and controls to put into place. Use our tools and resources to help develop and build an effective Anti-Bribery & Corruption programme.
Top-level Commitment: Leadership need to continually communicate their intention that bribery and corruption activities will not be tolerated. Those at the top of the organisation are in the best position to demonstrate to executives, middle managers, staff and the businesses with whom you work with to understand the importance, and the business and personal implications, of undertaking corrupt practices.
Risk Assessment: Carrying out a regular risk assessment is perhaps the most important step to ensure your Anti-Bribery & Corruption programme resources are effectively spent and your programme is fit for purpose. Key steps include researching the markets you operate in, evaluating the people and businesses you deal with, and rating your risks against impact, likelihood and frequency.
Anti-Bribery & Corruption Policies: Setting up the right policies and an engaging Code of Conduct are key components to getting your Anti-Bribery & Corruption programme in place. This includes knowing and clearly stating what your organisation will not tolerate and the steps of action when potential bribery is witnessed.
Proportionality & Controls: Adequate procedures as outlined in Anti-Bribery & Corruption regulatory guidelines is the key to designing a programme that provides adequate protection against corruption risk and implementing the appropriate controls and levels of due diligence. The actions you take should be proportionate to the risks you face and to the type of business and markets you operate in.
Third Party Due Diligence: Knowing exactly who you are dealing with will help protect your organisation against vendors and business partners that resort to unethical practices in order to win business. The regulators are taking a tougher approach on third party responsibilities and the checks you need to make before, during and after you engage with your business partners, customers and vendors.
Strong Organisational Culture: The reputation of any organisation rests on the work ethics of its employees and a strong organisational culture is the best way to ensure regulatory compliance. Communicate and train on ethical policies, understand your employee’s attitudes to ethics, help make ethical decision making an everyday occurrence, encourage speaking up within the workplace and act swiftly against unethical and retaliatory behaviour.