An organisation's Leadership takes the helm at ensuring that bribery and corruption cannot be part of company's business practices.

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On one part, the Leadership is in position to set the tone from the top and "walk the talk".

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On the other, the Leadership must be hands-on in addressing any actual or potential bribery risks.

In any compliance program, the Leadership must reinforce the organisation's anti-corruption stance as articulated in their Code of Business Ethics and ABC Policies.  These instruments outline the processes, procedures and responsibilities that employees must observe whenever business decisions are made.

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Other measures include:

• performing adequate due diligence on business third parties and high-risk transactions

• implementing financial and non-financial controls

• making available reporting channels

• transparency through documentation.

An entire organisation must be aware of its compliance program.  In this regard, regular communications of the company's policies, business ethics and procedures need to be conveyed through training, attestations as well as in business interactions, recognising commedable actions but disciplining unsanctioned behaviour, and so on.

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Whether an organisation is small, large or multinational, communication and training can be conducted in all forms of language that employees resonate with.  

Bribery risks exist in almost any situation relating to a company's business.  Organisations must therefore identify and analyse their risk areas.  For example:

• does your organisation operate in a perceived high-risk or highly regulated industry?

• your organisation's location(s) of operations, competitiveness in the market, the regulatory landscape

• types of potential clients and business partners

• are there any transactions with the government, payments to government officials?

• the use of third party intermediaries

• gifts, travel and entertainment expenses

• charitable or political donations.

The effectiveness of a compliance program must be consistently tested, reviewed, monitored and improved upon. 

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Enforcement of the compliance program is absolutely fundamental. 

 

It is encouraged to incentivise exceptional compliant behaviour (through promotions, recognition/ rewards program).  Likewise, disciplinary actions must be taken (like termination of employment) on those who flout the Code of Ethics, ABC policies or applicable laws.