Key steps to building an effective anti-corruption training programme
GoodBlog | read time: 9 min
Published: 26 October 2022
Over the last decade, legislators have been placing increasing demands on companies to build robust procedures to combat corruption, with potentially severe consequences for those that fail to respond. In our experience, companies that are struggling with anti-corruption compliance are often struggling with the more fundamental question of how to properly embed policies and procedures into the business.
According to GoodCorporation’s benchmark, based on over 100 anti-bribery and corruption (ABC) assessments conducted internationally, almost 30 per cent of the procedures assessed for training employees on ABC policies were found to be inadequate. Anti-corruption training for third parties such as sales agents and joint venture parties was even worse, with over half the procedures deemed inadequate.
To help businesses tackle this and ensure that adequate procedures to prevent corruption are firmly in place, GoodCorporation offers a range of ABC training programmes and courses drawing on our knowledge and expertise of building and evaluating effective anti-corruption compliance programmes.
Why is effective anti-corruption training important?
Regulatory authorities agree that effective communication and training deters bribery. Authorities such as the U.S. Department of Justice (DOJ) and the UK Serious Fraud Office (SFO) consistently emphasize training as a critical component of effective compliance programmes. According to guidance from the Foreign Corrupt Practices Act (FCPA), companies should foster a “culture of ethics and compliance at all levels. By raising awareness of the risks and consequences of bribery, an organisation can make its expectations of conduct explicit and reinforce its zero-tolerance approach.
The first step in developing an effective anti-corruption training programme is to identify where the organisation is most at risk. This will ensure that appropriate resources can be allocated to develop targeted training programmes for the more high-risk parts of the business such as procurement, sales and marketing or government affairs.
When developing an anti-corruption training programme, GoodCorporation often starts with a workshop for senior executives across the different business functions that are most at risk from corruption. Conducted at group or local level as required, an ABC training workshop will facilitate a deeper understanding of the organisation’s potential exposure to corruption and help the company identify and prioritise its training needs. Such workshops can help an organisation manage its risks effectively while also ensuring that collective ownership is developed for managing and embedding best practice.
How does training help embed anti-corruption policies?
When developing a training programme, GoodCorporation often starts with a workshop for senior executives across different business functions. These are typically delivered at group or local level depending on the needs of the organisation. The workshops facilitate a deeper understanding of potential exposure and help prioritise training efforts. They also encourage collective ownership for managing corruption risks and embedding best practice.
For example, GoodCorporation developed and delivered a full-day workshop for a global aerospace and defence company. Using a tailored, risk-based framework, the session focused on due diligence and compliance monitoring. Participants were trained to assess ABC risks across business activities and adopt a practical approach to assurance.
“GoodCorporation has a thorough understanding of how to measure Ethical Business Conduct and to build this into the audit process.”
— Granville Hodge, Former Group Audit Director, BAE Systems
This kind of tailored training not only strengthens awareness but also supports teams in applying the policies effectively in their day-to-day roles.
What should anti-corruption training include?
Clear definitions: The best training programmes ensure that all the basic definitions and policy requirements are clear and properly explained. This should start with an explanation of bribery and improper influence and include other related issues such as conflicts of interest, facilitation payments and gifts and hospitality.
Legal context: It is also helpful to summarise the legal requirements and the consequences for individuals as well as the organisation of failing to comply, looking to the UK Bribery Act, FCPA and OECD Guidelines for guidance. For some organisations, this may mean explaining the legal requirements across different jurisdictions, making it important to develop your training programme with subject matter experts who understand these varying global requirements.
Tailored scenarios: To make the training both relevant and effective, make it clear where bribery is most likely to occur and include ‘real life’ scenarios, ideally tailored to the organisation, so that stakeholders develop a deep understanding of the potential risks and how to avoid them. Using subject matter experts to draft content and develop such scenarios will help build a training programme that promotes engagement and is relevant to the specific risks a business might face, incorporating “red flag” examples specific to your industry.
Organisational policies: Make sure that the organisation’s own internal rules and processes are fully explained. This is particularly important for areas such as gifts and hospitality and conflicts of interest. The training should also remind stakeholders where the relevant policies can be found, and who to contact should they require more information.
Speak-up: When it comes to corruption, silence is never golden. Encouraging speak-up is an essential component of any anti-bribery programme. An ABC training programme should include details of the company’s reporting channels or whistleblowing line as well as reminders of the internal system for raising concerns with line managers or other senior leaders.
What form of anti-corruption training is most effective?
While much has been written about the pros and cons of online or face-to-face training, the key element of an effective ABC training programme is to ensure it is appropriate and relevant to the organisation’s culture, budget and geographic spread. Whatever form of training is developed, it should incorporate questions and answers as this promotes engagement, raises awareness and deepens understanding of the critical issues.
Face-to-face workshops: If budgets allow, face-to-face training can be the most effective, especially for leadership and high risk roles. In person training often allows for critical issues to be explored in-depth, promoting greater interaction among participants. It also allows the organisation to gauge the levels of understanding and identify what works well and what could be improved for the future.
Interactive webinars: For large, international organisations, ABC training webinars are particularly efficient and can be cost-effective for global teams. Webinars can be developed to incorporate interactive break-out sessions, Q&As and scenario-based learning, all tailored to the needs and risk profile of the organisation. These should be conducted in the appropriate language and tailored to incorporate local issues.
Online training: For many organisations, however, in-person training across the whole workforce may be inappropriate, unaffordable, or both. In such cases, online anti-corruption training can be carefully developed to communicate the organisation’s key anti-bribery messages and help meet compliance obligations. E-learning is also particularly effective for training sales agents and intermediaries, whose relationship with the organisation may require sensitive management. It can be easily scaled and tracked across a wide range of stakeholders, helping organisations ensure consistent messaging and monitor completion rates for audit or reporting purposes.
Who needs anti-corruption training?
One of the first principles to understand when embarking on an anti-bribery and corruption (ABC) training programme is that it may not be necessary to train everyone to the same extent. As the UK Ministry of Justice Guidance on the Bribery Act states, training should be proportionate to the risks faced. While senior executives and those in high-risk roles require more in-depth training, there remains a minimum requirement to ensure that all staff are aware of the organisation’s anti-bribery policy and understand what is expected of them.
In some jurisdictions, such as France, identifying those most susceptible to risk is a legal requirement as part of the mandatory anti-corruption risk assessment. Ideally, a company would assess exposure across the business and ensure that those in higher-risk positions, along with the senior management team, receive detailed, tailored training.
A useful approach is to segment the training audience to match the level of risk:
- Tier 1: Leadership, compliance teams, and high-risk operational roles
- Tier 2: Mid-level staff, third parties, and agents
- Tier 3: General workforce — often covered through Code of Conduct training
This allows organisations to target their anti-corruption training effectively while ensuring that a baseline level of awareness is maintained across all employees.
How often should anti-corruption training be conducted?
Best practice suggests that anti-bribery training is conducted annually, however rather than simply repeating the same training programme each year, the most effective anti-corruption training will build on previous years, focusing on specific issues as needs arise to deepen awareness and understanding. GoodCorporation also recommends that anti-bribery training is offered as part of new staff inductions and also to new suppliers and contractors where there is a risk of corruption.
Companies should also consider updating and re-running training in response to any incidence of corruption.
How to tell if anti-corruption training is working?
One of the most obvious ways to assess the effectiveness of an anti-corruption training programme is to monitor incidents of bribery. However, it is too simplistic to assume that if no bribery is reported, the training is effective and no further action is required.
Having adequate procedures in place to prevent corruption requires a strong programme of monitoring and policy review. Best practice recommends regular internal and external reviews of procedures to assess how well policies are embedded and whether they are operating effectively in practice. These reviews form part of GoodCorporation’s anti-corruption services, supporting clients in the development of robust and proportionate ABC programmes.
It is also important to assess the training itself. Measuring training completion rates, running post-training knowledge surveys, gathering anonymous feedback, and monitoring whistleblowing system usage can all provide valuable insight into how well the training is understood and applied.
Organisations should also ensure there are no gaps in training among relevant stakeholders. Some companies run refresher courses or test staff knowledge periodically, which can be particularly useful for business functions most exposed to corruption risk. In some cases, participation in ABC training is incorporated into employee performance reviews to strengthen accountability and reinforce expectations.
Reinforcing anti-corruption training
Good communication is an essential component of an effective anti-corruption training programme. In addition to training sessions, whether delivered online or in person, organisations should ensure that their anti-bribery policies and principles are widely accessible. This includes making them available on the company website, intranet and other internal communication channels.
Bribery risks should be discussed periodically at team meetings, with regular reminders of the policies and procedures in place. Including this content as part of wider compliance updates helps reinforce key messages and encourages good practice across the business.
Many companies are also developing dedicated apps that provide access to key policies, such as the Code of Conduct or ABC programme. For large organisations with a dispersed workforce, this approach can be an effective way to make resources, including optional training, available to all staff.
The internal communications team has an important role to play in promoting anti-bribery policies. By incorporating relevant messages into the organisation’s ongoing communications programme, businesses can help ensure that expectations remain visible and that the right behaviours are embedded across the company.
Anti-corruption training for third parties
Managing corruption risks in third parties remains one of the most challenging aspects of corporate compliance. It is also where organisations are often most exposed, with many bribery prosecutions linked to activities in the supply chain.
In higher-risk sectors, it is increasingly common for companies to provide anti-bribery training to certain suppliers, particularly those identified as more exposed. E-learning can be a useful tool in this context, as it is easy to deploy, scalable, and allows organisations to monitor engagement.
At a minimum, all suppliers should receive the company’s anti-bribery and corruption (ABC) policy during the tender process. Best practice also recommends including ABC clauses in supplier contracts and providing access to confidential reporting channels. Clear guidance on expected behaviours and procedures should be made available to support suppliers in meeting the organisation’s compliance standards.
Sales agents and intermediaries can also present a significant bribery risk, depending on the sector and jurisdiction. As such, it is important to ensure they are included in all relevant ABC training. Wherever possible, training for third parties should be brief, accessible, and translated into appropriate languages. Even a basic level of awareness can help reduce risk and strengthen overall compliance.
The benefit of effective anti-corruption training
Failing to prevent bribery can lead to lasting damage, not just to organisations but to individuals and the communities in which they operate. With regulators around the world intensifying their efforts to compel organisations to implement effective anti-bribery programmes, ensuring that the relevant policies and procedure are firmly embedded is essential. This requires the allocation of resources to ensure that appropriate and proportionate training is offered across the organisation. Not only will this help mitigate any risk from bribery, it also demonstrates an organisation’s commitment to a no-bribery regime. A commitment that investors as well as regulators and indeed society at large are also seeking.
Conclusion
Effective anti-bribery and corruption training is an essential part of any compliance programme. It helps ensure that policies are understood and applied across the business and among third parties.
Failing to prevent bribery can result in reputational and financial damage, as well as legal consequences. Robust training is a practical and powerful way to mitigate these risks.
More than that, it demonstrates a company’s long-term commitment to ethical conduct – something regulators, investors, and society increasingly expect.
GoodCorporation’s anti-corruption training programmes
GoodCorporation offers a range of anti-corruption training programmes including face-to-face training, e-learning, workshops and webinars, all tailored to the needs of individual organisations. Our programmes are designed by subject matter experts, drawing on our extensive experience of building and evaluating anti-corruption programmes across multiple sectors and international jurisdictions.
We also help devise clear communication programmes designed to reinforce an organisation’s zero-tolerance approach to corruption and ensure compliance with anti-corruption legislation.
This combination of appropriate training supported by good communication is critical to developing an effective anti-corruption programme.
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