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Continuing the conversation on counter bribery and corruption

24 May 2024

National Conversation Week (23-29 May) is designed to get people talking. That’s why we’re taking this timely opportunity to remind you as employers to have open, honest, and consistent dialogue with employees around your organisation’s counter bribery and corruption policies. When you do, you’re better equipped to provide a crucial layer of defence against fraud risk and insider threat. Let’s delve into this a little more… 

What isn’t nice about an employee receiving a gift, especially when it is unexpected? An all-expense spared trip to a dream destination, the chance to step into the driver’s seat of a luxurious new car or being the talk of the friends’ WhatsApp group having been handed front-row seats and five-star hospitality to the biggest sporting event in the calendar. The catch? To retrieve the goods, all the employee has to do is ensure a specific vendor ‘wins’ a significant contract with your company. 

However, if an employee were to go through with any of the above, an offence would be committed under the Bribery Act 2010. 

The Act, introduced in 2011, is defined as ‘giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so’. This guidance goes on to say that organisations could also be liable if, ‘a very senior person in the organisation (for example, a managing director) commits a bribery offence.’ 

Four ways to help prevent corruption and bribery occurring in your business 

Fostering a strong anti-bribery culture that makes your workforce its first line of defence is crucial, however, it’s one piece of the puzzle. Implementing effective strategies to prevent bribery, corruption, and insider threats is equally important. Here are four to get you started: 

1. Implement a way to declare gift items 

Like most companies, you might have a gifts and hospitality register already in place, however it’s vital you understand what your organisation’s risk appetite is so you can put effective measures in place that’ll ensure employees can declare certain offerings. In doing so, the person receiving the gift can understand the purpose of the item and that it’s not influencing in any way. Effective ways to record gifts include filling out declaration forms, inputting the detail into an accessible online portal, or seeking sign-off via an approvals process with managers. 

2. Maintain effective policies 

Develop clear and comprehensive policies and procedures that underpin what constitutes bribery and corruption, and make sure they’re reviewed, updated, and communicated regularly. Doing so can further help your employees and any third parties to understand what they should and shouldn’t be doing to not only further protect themselves, but your organisation too. 

3. Encourage confidential ways to report dishonesty 

It’s important to support employees throughout so that they feel confident to report something if they witness an incident of a colleague’s dishonest conduct before they become an insider threat. Establishing a mechanism that enables staff members to escalate concerns confidentially to their managers and/or encouraging them to utilise your organisation’s whistleblowing service – without fear of reprieve – can help them to speak up and provide an additional layer of safety throughout. 

Whilst these services might not be used all the time, recent Cifas research showed that a third of UK people (32%) would report a colleague if they’d found they’d been dishonest. 

4. Improving training and awareness 

Educating employees to recognise red flags, understand the dangers of bribery and corruption, and how to report suspicious behaviour can further reinforce your message. Whether you need to introduce or update frameworks and strategies, if you’re not sure where to start, we can help… 

The Cifas Fraud and Cyber Academy delivers a ‘Professional Certificate in Counter Bribery and Corruption’ qualification designed to help manage bribery risks and respond when it’s detected in any form – from initial investigation, through to response and action. Find out more

Meanwhile, our ‘Internal Fraud Strategy Essentials’ course provides the critical information and skills needed to help you build the foundations to defend against the insider threat. See how this course can benefit your organisation

Additionally, book onto our Digital Learning programme – a game-changing immersive experience that enables viewers to bolster their fraud awareness. Our ‘Business Awareness’ course has a section on preventing bribery and corruption and guarding against the insider threat. Book your free 7-day trial

Finally, make sure you read the insights from Rachael Tiffen, our Director of Learning and Public Sector, on anti-corruption and bribery training, here

Of course, the above is only a snapshot into the measures you can put into place to counter these specific internal risks. However, take the time to review what you already have within your operations and explore a little further. For example, think about the due diligence you conduct on third party vendors, suppliers, and partners – is it robust and detailed enough? Can your financial controls detect dishonest conduct before it’s too late? Throughout, make sure you set the tone as an employer and leader by underlining your organisation’s stance against bribery and corruption. 

Posted by: Tracey Carpenter

Tracey is Cifas' Insider Threat Manager


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Posted by: Tracey Carpenter

Tracey is Cifas' Insider Threat Manager