Anti-Bribery and Corruption Compliance Training
Corruption is the abuse of power – or the inducement to abuse power – for personal, political, or commercial gain. Bribery is a specific offense that involves the exchange of something that has value to the receiver. It’s given in the hope of getting something in return.
We offer a global anti-bribery compliance training & anti-corruption compliance training course that references the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act, as well as other international anti-bribery training and anti-corruption training policies and legislation, such as Sapin II in France.
This interactive, engaging anti-bribery compliance training course and anti-corruption compliance training course will ensure employees at all levels understand their roles and responsibilities in protecting your business from the risk of bribery and corruption.
What Is Anti-Bribery & Corruption?
Video: Overview of what bribery and corruption are. Impact on society. Never acceptable. Everyone is responsible for conducting business in an ethical and honest manner.
Scenario: Taking a foreign government official for a lavish dinner as a show of appreciation.
Key Learning: Business dinners may be appropriate but must be within guidelines. Contact details for questions around offering hospitality.
Scenario: Invitation from a local government official to a fundraising dinner for a local charity.
Key Learning: It is your responsibility to know what type of situations you need to escalate, and who you need to escalate to.
Consequences of Bribery & Corruption
Interactive Screen: Economic and social effects of bribery and corruption and the fact that they are crimes around the world. Consequences for companies and individuals found guilty. Our policies help protect us.
Scenario: Working with an overseas agent.
Key Learning: An intermediary cannot shield you or the company from acts of bribery or corruption.
Scenario: Vendor offer of an internship for a family member.
Key Learning: This could give the appearance of, and possibly result in, a corrupt situation.
Scenario: Low-cost gifts for clients (i.e., cheap ballpoint pens or T-shirts).
Key Learning: Value of the gift in the giver’s eyes is irrelevant – the value to the recipient is the important factor.
Interactive Screen: Types of risk are based on location or are specific to country; are related to industry or situation; and are based on people or relationships.
Scenario: Possible facilitation payment.
Key Learning: A facilitation payment can be considered a bribe. Always identify and assess the level of risk by considering the countries and people you are dealing with.
Scenario: Risk of bribery or corruption for a high-risk role within a high-risk industry for a company with well-structured policies, procedures, and systems to prevent bribery.
Key Learning: Always assess the level of risk by considering the industries and people you are working with.
Scenario: Risk of bribery or corruption for company that went through rigorous screening process to become an authorized supplier.
Key Learning: Due diligence is a continual task and not just a one-off exercise. You must be able to identify high-risk activity and understand when and how to escalate this type of issue.
Interactive Screen: Some locations pose a greater risk than others. CPI, assessing risk, red flags, and mitigation.
Scenario: Conducting a corruption risk assessment.
Key Kearning: CPI ranks countries by the perceived levels of corruption. If you work in a high-risk location, be aware of the heightened risks. Contact details for questions.
Cash, Gifts, & Entertainment
Interactive Screen: What is considered a bribe? What counts as gifts or entertainment? What to do if you have any doubts.
Scenario: Identify the expenses that could be perceived as bribes.
Key Learning: There is no minimum value for an improper payment in any form to be considered a bribe. Any offer or promise of something of value is sufficient to be considered a bribe.
Tactics to Prevent Bribery & Corruption
Video: Overview of tactics to prevent bribery and corruption. YOU are the most important control against bribery and corruption. Awareness of risk, ability to spot red flags, and willingness to speak up.
Interactive Screen: Red flag statements and actions to watch out for. Always speak up.
Key Learning: How to respond to a request for a gift from a government official.
Scenario: How to respond to a request for a gift from a government official.
Key Learning: Giving a gift of a bottle of wine, even a cheap one, to a government official to speed up the permit approval process could be seen as a bribe.
Scenario: How to respond to a request for a cash payment from an official to expedite a customs process.
Key Learning: If a payment is going to an official’s agency or department with some sort of agency form or application, it is likely to be a permissible payment; but if it is going in the pocket of the official, it is likely to be considered a bribe.
Scenario: How to mitigate risk in bribery situations.
Key Learning: Never comply with requests for extra funds for expedition of services. Making an agreement to comply with bribery requests still counts as a bribe, even though no bribe has been given.
Books & Records
Interactive Screen: Importance of accurate record-keeping for anti-corruption training. National law and company policy set record-keeping standards. Everything must be thoroughly documented. Dealing with government officials. Always keep proper records.
Scenario: Payments without receipts made by a third party on our behalf.
Key Learning: We can be liable for actions of third party. Unusual payment requests raise a red flag and may indicate that the true nature of the transaction is being concealed.
Scenario: Handling a gift of dinner vouchers received as a goodwill gesture.
Key Learning: Check company policy around record keeping and keep the right records in the right way.
Politically Exposed Persons
Interactive Screen: Who are PEPS? How to identify a PEP. Dealing with PEPs. Obtaining senior management approval to work with a PEP.
Scenario: Risk of dealing with someone who is a close relative of a PEP.
Key Learning: A family member of a senior executive holding a position in government potentially exposes our company to the risk or perception of corruption and should be reported.
Scenario: What action to take when you discover an agent you are dealing with is related to a PEP.
Key Learning: Identifying a PEP does not mean you cannot do business with them, but it does mean that additional investigation and ongoing vigilance are required.
Corrupt activity, bribery, or attempted bribery is never acceptable for legal, moral, and ethical reasons. Each and every one of us has a responsibility to ensure that all our business relationships are conducted in an ethical and honest manner.
Failure to do so harms society, your company, your colleagues, and you. Employees need to be able to recognize red flags for bribery and corruption so they can protect the company, their colleagues, and themselves.
Online anti-corruption compliance training is an effective way of providing a clear, consistent message to your employees, whether in the US, UK, Europe or Asia, about their role and responsibilities around anti-bribery and corruption.
There are multiple tactics to prevent bribery and corruption. Some are externally imposed, such as the requirements in national laws and regulations like the FCPA, UK Bribery Act, or Sapin II in France. Others, like anti-bribery policies, procedures, systems, and training, are internally adopted.
Your employees are the most important control against bribery and corruption. Without them, all anti-bribery laws, regulations, and policies are meaningless; so making sure your employees are well trained is a critical line of defense.
By giving employees engaging and relevant training, you help them prevent bribery and corruption by making them aware of the risk, enabling them to spot red flags, and encouraging them to speak up.