Bribery and Corruption
When your organization is aligned on anti-bribery and corruption policy, training and third party risk, your employees can identify, report—and ultimately stamp out—bribery and corruption.
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Challenge of addressing bribery & corruption
Bribery and corruption can happen anywhere in the organization, but it tends to be most prominent in teams that engage with or operate overseas and interact with government officials. Doing business globally has opened up organizations to new rewards, but also to new risks.
The U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act set the general parameters for defining bribery and corruption around the world. These acts set the guidelines for how to identify, avoid, report and prevent bribery and corruption, how organizations should open reporting channels for employees and third parties, how to drive awareness and education on the topic, and how to maintain accurate records that can help protect the organization if incidents arise.
Failure to take responsibility for your organization’s internal and external dealings can often end in damaging allegations, unwanted media attention and continual investigations. Many of the corruption scandals making headlines could have been handled more effectively with clear policies against bribery and corruption on the front end and a safe place for employees to speak up if they do see bribery or corruption. Employees and third parties need clarity around what steps to take if they witness misconduct through training, policies and a process to report. Knowledge is power and, in this case, protection.
What you need
Policy
An unambiguous anti-corruption policy easily accessible and understood by your employees and third parties that is readily updated as needed.
Training
Training for employees and third parties on how to spot, report and prevent bribery and corruption.
Communication
An organizational definition of what constitutes bribery and corruption and consistent communication through globally accessible training.
Vendor Oversight
Strategies to vet and evaluate third party bribery and corruption risks and processes to limit potential impact.
Safe Way to Speak Up
A secure and anonymous channel through which employees and third parties can report bribery and corruption concerns.
Report Management
A secure conduit through which bribery and corruption reporting can be gathered, monitored and managed.
Steps you can take to build an anti-bribery & anti-corruption program
Step 1
Define acceptable behavior within your organization and with your third parties. Because bribery and corruption failures can be devastating to the organization in terms of governmental enforcement and reputation, it is critical that your anti-bribery and corruption policy is unequivocal.
Step 2
Ensure that your employees and third parties are aware of your bribery and corruption policy specifics, how it applies to them, and how to report concerns.
Step 3
Deliver targeted ethics and compliance training on your policies and how to avoid, spot, report and prevent bribery and corruption.
Step 4
Monitor your bribery and corruption program for new and emerging risks, adapt your policies and training accordingly and review your employee and third party reporting for incidents and trends.
Sample Policy
Anti-Bribery Sample Policy