This resource will explore what constitutes an effective Anti-Bribery and Corruption (ABC) Program.
In most, if not all jurisdictions, bribery, and corruption is illegal. In this respect, contracts of employment and workplace policies, like codes of conduct, often prohibited any form of bribery and corruption. However, when considering what forms an effective approach to combatting bribery and corruption, simply having a stated position that such conduct is prohibited arguably does not go far enough. As a result, organisations need to consider how they can ensure that they have put in place effective controls to prevent bribery and corruption taking place.
The question that follows therefore is what constitutes an effective Anti-Bribery and Corruption (ABC) Program? Although there are numerous controls (most of which are effective in one way or another) to support an ABC Program, fundamentally, four main controls should be implemented to act as the primary shield against bribery and corruption.
While other controls, such as internal audit, can be highly effective, the four controls above act as the ‘pillars’ of any successful ABC Program. Often, organisations find the implementation of a ABC Policy and standing up a hotline to be relatively easy tasks to do, however, neglect the importance of training staff and leaders on the ABC Program. This is often a by-product of a lack of capability or capacity to develop programs or the uncertainty / difficulty to lock in days to conduct training.
Unfortunately, failing to implement and carry out training can lead to a devaluation of an ABC Program. This is because staff and leaders need to understand what anti-corruption means and why it is important and make personal commitments to ethical behaviour. Undertaking ABC training for all staff will ensure that the organisation’s staff is fully educated about bribery and corruption and their various forms, the implications of taking a bribe or acting in a corrupt manner and how instances of such behaviour can be reported.
Importantly, whether the training is being conducted for senior leaders or general staff, for the ABC training to be effective, it needs to resonate with the participants. This means that individuals need to relate to the material presented in their training
In summary, organisations should be proactive in organising training for leaders and all staff on their ABC Programs. Where possible, face-to-face training is always preferred as it gives the opportunity for interactive sessions where key learnings and principles can be imbedded through discussions and case studies. However, practically this may not be possible, especially in the context of the all staff training in large organisations. As a result, organisations may have to take a pragmatic approach where face-to-face training is conducted for senior leaders and a learning module approach is undertaken for all staff.
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