Building effective procedures to combat corruption can be a challenge particularly for large organisations working across multiple jurisdictions. Recognising the importance of sharing best practice globally, Gulf-based business organisation Pearl Initiative asked GoodCorporation to design a series of eight, one-hour webinars on combating corruption.
The content of the webinars was based on the findings of GoodCorporation's white paper Combating Corruption: Businesses still at risk.
The paper highlighted the areas where businesses were succeeding at putting effective measures in place to prevent corruption compiled from the results of over 100 anti-corruption assessments carried out by GoodCorporation. It identified the anti-corruption practices that had improved over the previous five years. However, it also found a number of critical areas where companies were struggling to implement effective processes, so putting organisations at risk from corruption and possible prosecution.
The Combating Corruption webinar series turned the findings of this paper into practical advice for companies. Each procedural area was explored in turn, with best practice guidance provided by GoodCorporation's senior business ethics consultant Michael Pollitt. This was followed by an in-depth discussion with a range of expert speakers from the worlds of business, law, banking and academia.
The eight webinars covered the following key areas.
The importance of robust due diligence
With due diligence of third parties still the least adequate of the anti-corruption practices GoodCorporation has assessed, this webinar examined the findings in the paper, exploring how and where due diligence systems most often fail. Best practice was explored in detail with examples given of challenges overcome. Mohamed Daoud, Business Development Director, Governance Risk and Compliance of Refinitiv joined Michael Pollitt for the discussion.
The role of risk assessment
A company that fails to carry out a meaningful anti-bribery and corruption risk assessment cannot be confident that its controls are fit for purpose. Yet 40% of anti-bribery risk assessment procedures assessed by GoodCorporation have been found to be inadequate. This webinar identified the most common areas where companies go wrong and showed how best practice can be implemented. HSBC's head of Legal Structuring and Strategic Finance joined shared the HSBC perspective.
Embedding compliance through training and communication
Companies that struggle with anti-bribery and corruption compliance are often struggling with a much more fundamental question: how to embed compliance into their culture. Updated guidance on the Foreign Corrupt Practices Act calls for businesses to "foster a culture of ethics and compliance with the law at all levels of the company". This webinar examined why this vital aspect of anti-corruption practice matters and how to implement an effective programme. Forensic Accountant Geetha Rubasundram shared her experiences of embedding effective compliance.
Approaching regulatory affairs and government
Although the OECD and the UK Bribery Act both focus on the specific issue of companies bribing public officials abroad, this is an area of anti-corruption practice that is often inadequate and remains one of the top three reasons why companies fail a GoodCorporation assessment. This webinar explored the controls that companies struggle to implement effectively and provided examples of best practice that can be implemented in this complex area. Amine Antari, Managing Director of Kroll joined Michael Pollitt for the discussion.
Safeguarding sales and marketing
From an anti-corruption perspective, sales and marketing can present a significant risk. This was an area where anti-corruption controls had deteriorated in the five years between 2014 and 2019. This webinar examined why some companies are falling behind, looking particularly at how sales agents can be managed to minimise risk as well as other areas of recommended best practice. Mohamed Daoud, Business Development Director, Governance Risk and Compliance of Refinitiv joined Michael Pollitt for the discussion.
Putting human resources at the heart of compliance
Exchanges of gifts, offers of hospitality, recruitment dilemmas and conflicts of interest are all key areas of corruption risk which pass across the desks of the human resources function on a daily basis. Many organisations have a long way to go in building effective systems to prevent corruption and mitigate risk in this area. This webinar explored the practical steps companies can implement with a discussion on the challenges with Mohamad Mansour, Chief Compliance Officer of Power Bank.
First lines of defence in finance and procurement
Properly embedded finance and procurement controls provide one of our most important lines of defence against corruption. In many organisations assessed by GoodCorporation, this is one of the most effectively implemented anti-bribery procedure. However, the gap between the best and worst performing companies is large. This webinar examined some of the the weaker controls and explored how to implement best practice. Adam Malouf, Chair of the Middle East Advisory Committee of the Australian Institute of Company Directors shared his perspective on this critical area.
Monitoring compliance through effective whistleblowing
Companies with weak monitoring procedures not only face the risk that bribery will occur. They also face the risk of a weakened defence if brought before the authorities. Establishing an effective whistleblowing system can be critical to an anti-bribery monitoring programme. This webinar explored why some systems fail and what steps are needed to make whistleblowing work. Nina Nikolic, Legal and Compliance Manager for Novo Nordisk joined Michael Pollitt for the discussion.