These days, companies from all types of industries are coming up with their own anti-corruption compliance programs; but how do we know when an anti-corruption compliance program actually works as it is supposed to?
Your company?s anti-corruption compliance program can be overly complex, can somewhat be needing some more work, or perhaps it is just the right balance; one thing is for sure though, success can?t be guaranteed by having an effective program alone.
How so?
Fraudsters will find a way to circumvent an effective program and will do everything to avoid detection ? to the point of paying bribes. This is where embracing an anti-corruption compliance program comes into play, but then, it is also vulnerable to a host of problems.
One such problem is when the leaders of the organization develops tunnel vision and thus relies so heavily on the program that they forget all about continued risk mitigation and exercising vigilance. When this happens, the organization is left vulnerable to fraudulent activities.
So what are the red flags that your organization may be suffering from tunnel vision as far as an anti-corruption compliance program is concerned? We?ve got that covered below:
Lack of Follow Through by Senior Leadership and CEO
Just having a program isn?t enough when the leadership does not understand how the program is supposed to work and what it takes to make it work. The absence of senior management commitment and ownership will render the program ineffective.
Business Managers Have Not Embraced Compliance
The best way to gauge a company?s commitment to compliance (on everything, and not just anti-corruption) is to see if the business managers are doing their part in ensuring compliance with anti-corruption laws and policies. This is especially true in sales. Business managers who do not monitor employee activities and don?t care to remind everyone of the policies are basically not taking any accountability for whatever happens with the program.
Disconnection Between Financial Controls and Anti-Corruption Compliance
Any potential unauthorized usage of funds should be monitored by CCOs, managers, and financial officers. Failing to do so by not having proper coordination of the anti-corruption compliance and financial controls can result to corrupt actions such as the company officials bribing government employees to gain favours or special treatment. Simply put, inadequate connection between financial controls and anti-corruption compliance can mean giving access to some funds to be used for bribery.
Lacking Due Diligence Process
If the due diligence program is not as it is supposed to be, it will be ignoring mitigation strategies and careful risk-based analyses. For instance, if the employees have no understanding of red flags and other possible signs of corruption, then there is no way they can report if they witness it occurring in the organization.
Having a Program for Reimbursement and Hospitality Expense
There is no real problem with simply having a reimbursement and hospitality expense program IF it requires pre-approval, has annual limits, and collects data of all interactions and meetings with recipients. Lacking these things can mean serious bribery risks.
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