If you have the policy sorted then its a matter of demonstrating that it has been communicated to the staff and a sign off system is required
So you should conduct anti-corruption compliance and awareness training
Anti-corruption training is a necessity and especially true for global organizations entering or active in countries with a history of corruption.
At a minimum, all employees and agents in a position to give or receive bribes, or to detect such activity, should receive anti-corruption compliance training
The training should highlight:-
• Corporate anti-corruption policies and procedures
• Details of how employees can get further guidance on matters
that they are unsure about
• Potential “red flags” or problem situations
• How to report and escalate potential violations
• That corruption will not be tolerated
You should consider a mixture of live training for some higher-risk employees and web-based training for all employees.
Senior management, employees in sales, marketing, finance, legal, M&A and internal audit should receive enhanced training, customized to their
particular roles.
The training program should be regularly updated and provided to new
or transitioning employees.
It should include a test, which must be passed, to demonstrate
that employees understand the concepts and practical implications of the material
Many companies complement their training programs with a certification program, whereby the employee certifies that he or she has taken the training, understands his or her responsibility and has reported any and all incidents of corruption that they are aware of
The sign off or certification is evidence that you have a implemented an anti-corruption policy and is understood by the staff
Demonstrating Effectiveness
The design, implementation and monitoring of an anti-corruption compliance program must be accurately documented
This documentation provides vital evidence of the organization’s commitment to meeting its requirements under applicable statutes.
In the event that potential bribery is identified, anti-corruption compliance documentation will help to demonstrate that the bribery was performed in violation of the company’s policies
The documentation may also show that the perpetrator knew or should have known that hey were in breach of company policy
In my experience, the effectiveness of anti-corruption compliance program is dependent on a clear requirement for consistency and a rigorous approach to documentation
Implementing a program that is not consistent or rigorous creates a greater risk for the business.
