Companies doing business internationally must increase their
level of care on anti-bribery and all anti-corruption scenarios, especially
when operating in locations that might be prone to irregular behaviours.
In 2016, the International Organization for Standardization (ISO) released the first set of standards designed to help organizations prevent and detect bribery. The ISO 37001 standard might become the proper benchmark for assessing and managing anti-bribery and corruption systems.
Corporations should consider some of these specific measures:
— Internally
(and externally) assess the level of corruption risk in the operating country
(corporate risk mapping, or simpler tools such as Transparency International’s Corruption Perceptions Index).
— Send a
strong message to international business managers by setting a strict standard
of behaviour and principles to be applied globally.
— Apply a
proper anti-corruption policy adapted to the industry or sector (Code of
Business Ethics), through benchmarking and risk assessment and previous
sanctions analysis (a proper review of past FCPA sanctions).
— Closely
verify the track record of outsourcing providers, local agents, distributors or
intermediaries. In case of convictions for corruption offences, these companies
should be excluded from the providers list.
— Train the
local management and employees on anti-corruption policies (the company’s and
global standards). These training sessions are normally held once a year, and
should be provided in the local language to guarantee the understanding of the
policies.
— Provide a
follow-up system and mechanism to verify that the policies are being properly
followed, including third-party contracts.
— Conduct periodic performance tests (audits) as well as public industry reports to be delivered to public authorities and other relevant parties.
Most major companies have already introduced and are performing most of these tasks. However, without a constant, independent monitoring of all involved parties, there is always a risk that some element of the chain might fail. A proper anti-corruption culture must be the credo of the corporation, providing recurring due diligence exercises, internal audits and the realization that the constant upkeep of these policies is the only way to reduce any negative outcome.
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