How alarmed would you be if you saw this headline: “Nine out of ten organizations don’t provide anti-corruption training for high-risk employees”? Well, that’s just one of the startling findings of a recent report, “International Business Attitudes to Corruption,” which was based on a survey of more than 300 companies from around the world. Just as alarming is the fact that 74% of respondents said their organizations had no anti-bribery training program in place – at all!
About one-third of the respondents surveyed were in the Asia-Pacific region, one-quarter in Europe, and about 15% in North America. They included corporate counsels and compliance officers from a variety of commercial sectors.
As would be expected, the issue of “operational bribes” was one of the biggest concerns reported. This form of corruption falls under the category of facilitation payments, which continues as an area requiring further clarification. The next largest area of concern is third-party risk, which was consistent across all geographies.
It’s obvious that some organizations are still operating in dark times when it comes to their anti-corruption efforts. These companies run the real risk of appearing in their own headlines, something to the tune of “[INSERT COMPANY NAME HERE] to Pay $XXX Million for Corrupt Practices in [INSERT REGION HERE].” Check out these other stats from the report:
- Only 50% maintain third-party due diligence procedures
- Only 30% thought it was “very unlikely” they would be investigated for bribery in the next two years
- 35% do not have anti-bribery policy statements at all and 47% do not have policies which prohibit “facilitation payments”
- 36% do not refer to anti-bribery statement in their contracts with sub-contractors and consultants
- Only 40% have confidential whistleblower hotlines ready to take reports concerning corruption
These stats should be setting off alarm bells for compliance leaders. They touch upon all of the elements we talk about as being absolute necessities if your compliance program is to be effective as a means of defense for your organization. Those companies in the 26% that don’t have an anti-bribery training program in place have no good way to explain the risks to their employees or show them how to conduct ethical business in a corruption-laden environment. Employees in high-risk areas must know and be apply to apply your anti-corruption policies, leveraging what they’ve learned in anti-bribery training. Then you must perform third-party assessments so you know better how to help those employees stay out of harm’s way.
International legislation is getting tougher every day, and organizations had better heed these kinds of warnings or else risk seeing their name in the headlines.