The Need for a Top-Down, Transparent Due Diligence Program for Communications
with all Stakeholders.
Is your business prepared to launch a due diligence/anti-corruption
program?
The potential for revenue growth in
emerging markets can be tempting. However, there is a material risk related
issues of alleged bribery, fraud, and corruption (BFC) to ruin the goal.
Due diligence can be the answer along with additional research, development
and testing 3rd party compliance in dealing with bribery regulation, compliance,
and risk-management issues in multiple jurisdictions.
Create a culture of ethical conduct
The best way for a company to minimise the risk of BFC prosecution is
to establish a compliance program that places 'adequate procedures' in
place to prevent acts of corruption and bribery. The next step is to understand
and create a culture of ethical conduct that integrates and embeds the
day-to-day operations in the country in sight. The transparency and accountability
components can be used as tools to communicate the approach to all employees
and global partners within the business and organisation.
Trends
It is not just the U.S. Department of Justice and the Securities, Exchange
Commission or The UK Fraud offices that are ramping up enforcement of
anti-corruption laws. Enforcement agencies in the UK, Brazil, China, India,
are also strengthening their anti-bribery and corruption oversight, implementing
new directives, and hunting down violators with unprecedented enthusiasm.
Recent news proves that some countries are working together and share
information for joint legal actions.
Be vigilant and measure, monitor, and manage
The globalisation of corruption enforcement is a new enforcement trend.
Some of the recent settlements with the Department of Justice and the
SEC of Foreign Corrupt Practices Act charges for FCPA enforcement are
also alarming. Therefore, businesses must be vigilant and measure, monitor
and manage all these enforcement risks. Third parties due diligence and
providing more training on anti-corruption policies and practices to employees
is simply not enough anymore.
We suggest a workshop that addresses the following:
- Examine the real-life Bribery and corruption compliance scenarios
that have challenged the company executives
- Leverage their existing experiences and skills and develop practical
solutions
- Moderate group discussions that encourage peer learning based on
the experiences and scenarios
- Offer detailed insight on the consequences to all stakeholders
- Develop an interactive approach to making the participants absorb
and understand the solutions in a practical context
- Equip the frontline employees with the above tools to put their
new skills to use.
For more information see: http://www.riskability.org/2016/csr-anticorr/