As stated above, the UK Bribery Act means that many firms will now have to ensure that they have adequate procedures and controls to prevent bribery and corruption.
The UK Act sets out six principles
- Top-level commitment
- Risk assessment
- Communication
- Due Diligence
- Monitoring and review
1) Top-level commitment:
The Ministry of Justice (MoJ) advises that your business will need to show that it has been active in ensuring that staff and key business contacts understand that you do not tolerate bribery.
2) Risk assessment:
This shows you have considered the possible risks you face as a company, especially if you are entering into new business arrangements.
3) Communication:
Communicating your policies and procedures to staff and others who will perform services for you.
4) Due Diligence:
Knowing who you are dealing with can help protect business – so it’s advised that you do a few checks and ask a few questions before engaging others to represent you in business.
5) Monitoring and review:
You may want to keep an eye on any anti-bribery steps you take so that they keep pace with any changes in the risks your business faces.
Barriers to implementing AB&C policies:
– Competitive advantage
– Managerial apathy
– Off-the-shelf solutions
– Corporate structures
– “Shadow” hierarchies
– Excessive pressure to hit targets
– Cultures of secrecy
– Heterogeneous cultures
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