How to Strengthen Anti-Corruption Compliance Program?
2019-05-06 09:57 Monday
Anyone running an anti-bribery compliance program needs to know where to focus their resources. Law enforcement has always believed that anti-bribery efforts should be proportionate to the risks, and that being too cautious with minimal risk could distract teams from areas where they are more likely to get into trouble.
So how do you measure these risks?
The first is to study national risks. An important starting point is to identify compliance risks in specific markets. The risk of corruption varies around the world. Transparency International's Corruption Perceptions Index, the world bank's global governance indicator, and TRACE International's own Bribery Risk Matrix are just some of the ways companies can get corruption rankings across countries.
For those doing business around the world, these rankings help to consider how likely they or their companies are to be involved in illegal activities.
Second, review all intermediaries. Involvement in corruption is often the result of agents or intermediaries acting without proper scrutiny or supervision.
Intermediaries can be corrupt or weak in the face of temptation and financial pressure. In any case, if there are signs that the risks to the company have increased but are not being heeded, prosecutors will knock on the door first.
Other areas - such as the quality of law enforcement, transparency of government procedures, free media participation and strong civil society -- represent a wide variety of policies and incentives that can make bribery more costly and therefore less risky to comply with.
In daily deals, lower-level officials have plenty of opportunities to extort bribes, anticipating that their demands will be met, and having the ability to delay a project if they don't.
In this case, thorough training becomes critical. Employees and agencies need to know that the companies they represent neither pay nor tolerate bribery on their behalf.