View from the top: Transparently honest - What makes a strong anti-bribery programme?

I was working as head of internal audit for a multinational company, which had a diverse workforce and an extensive global presence. It soon became clear that it required a robust anti-bribery programme to maintain its ethical standards, mitigate risks and uphold the organisation’s reputation. We therefore set out to design a programme that would cover employees across different hierarchies and geographical locations and ensure a consistent and cohesive approach to combating bribery and corruption.

I believe other organisations could benefit from our experiences, so, while respecting the confidentiality of the organisation, I hope that outlining its challenges and needs will enable other internal audit leaders to understand the environment in which the programme was implemented.  I hope this practical advice based on personal experiences will help others seeking to enhance their anti-bribery measures.

Why did we need a new anti-bribery programme?

This decision was motivated by several factors. First, the external environment was shifting and there was an increasing emphasis on transparency, integrity and accountability in business practices. This changing landscape heightened our awareness of the risks associated with bribery and fraud. We believed we needed to take proactive measures to protect the organisation’s interests.

The challenges

We faced several challenges. First, we had to ensure that employees across many countries and business units understood and adhered to the programme’s principles. This required effective communication and training. It was critical to overcome language and cultural barriers to promote a consistent understanding of anti-bribery policies
and procedures.

We also had to conduct due diligence on our business partners, suppliers and intermediaries and this posed logistical challenges. Managing relationships with third parties in different jurisdictions demanded a thorough understanding of local regulations and customs, as well as effective monitoring mechanisms to detect and address potential red flags.

Setting up a comprehensive anti-bribery programme requires a proactive and strategic approach, which takes into account the specific challenges and needs of your organisation. My experiences taught me that beginning early, conducting risk assessments, developing clear policies and robust controls, encouraging reporting and providing continuous training are all vital to ensure your anti-bribery programme is a success.

Obviously, different organisations’ needs vary, but a comprehensive anti-bribery programme will protect every organisation’s integrity, mitigate risks and help it to maintain a reputation built on ethical practices. A proactive stance against bribery and corruption is about more than simply meeting your legal and ethical obligations. It is about contributing to long-term sustainability and stakeholder trust.

Practical advice.

Based on my own experiences, I would suggest that any internal auditor seeking to enhance their organisation’s anti-bribery measures should
consider this advice.

1. Start early. Initiate the development of an anti-bribery programme as early as possible. Delaying implementation may leave your organisation vulnerable to risks and potential incidents.

2. Conduct a risk assessment. Prioritise conducting a comprehensive risk assessment to identify the specific bribery and corruption risks your organisation faces. If you don’t do this first, it will be harder to tailor your programme to address these risks effectively.

3. Develop clear policies and procedures. Craft clear and concise anti-bribery policies and

procedures that are easily
understood and easily accessible to all employees. Regularly communicate and reinforce these guidelines through training programmes and awareness campaigns.

4. Establish robust controls and monitoring mechanisms. Implement strong internal controls and monitoring mechanisms to detect and prevent potential instances of bribery or corruption. Regularly review and update these controls to adapt to changing circumstances.

5. Encourage reporting and publicise comprehensive whistleblower protection. Foster a culture of transparency and accountability by establishing confidential reporting channels. Ensure that people who speak up are protected – and that potential whistleblowers are aware of this protection. It is vital that employees are not only encouraged to report suspected incidents of bribery or corruption, but that they know they can do so without fear of reprisal.

6. Provide continuous training and awareness. Ongoing training and awareness programmes will ensure that employees (and internal auditors) understand the evolving risks and current best practices in preventing bribery and corruption. Reinforce the importance of ethical conduct throughout the organisation.

Further information

The Chartered IIA runs a course on Auditing Fraud and Financial Crime.

For more on whistleblowing see the Chartered IIA’s position paper on Internal Audit and Whistleblowing.

IIA Global has produced a joint report with the ACFE on Building a Best-in-Class Whistleblower Hotline.

This article was published in September 2023.