In the world of anti-corruption compliance, it is becoming increasingly clear: companies must have robust business processes in place that extend throughout the organization. The much-publicized corruption and bribery cases over the past few years have shown that lack of effective practices , not just policies, can put a company at risk. A solid compliance program supported across the organization, though, has the potential to stop corruption.
The challenge for many companies is this: how do you move beyond a paper-based compliance program? Historically anti-corruption compliance has been the responsibility of a company's legal or compliance department. Increasingly, however, companies are realizing that cross-functional representation on compliance teams is an important factor in achieving effective implementation of their anti-corruption compliance programs. While it can be a challenge for compliance leaders to engage their colleagues in other functional areas of the company, effectively implementing an anti-corruption compliance program requires company-wide input.
As many commentators have noted, cross-functional teams are better positioned to:
- build awareness of the anti-corruption program among employees;
- create alignment between the compliance message and actual behaviors;
- help ensure training is meaningful and tailored to all employees and the specific risks they face;
- provide practical support and guidance for employees with questions or concerns; and
- report and follow up when problems arise.
Realizing this, companies are using a number of approaches to get input from different functional areas. Some have constituted 'councils' or committees to give regular input to the compliance officer. Others hold quarterly compliance roundtables. Whatever form a company chooses, it may be useful to get input from supply chain and procurement, legal, finance and accounting, human resources, marketing, sales, communication, all of whom – as a practical matter – share responsibility for implementing – and ensuring compliance with – the anti-corruption program. The cross-functional alignment may also include establishing overall goals for the program and developing measureable metrics for success.
Cross-functional representation is particularly important vis a vis sales and marketing and procurement, areas in which companies are working with third parties, a significant source of corruption risk. Getting input from those units – asking questions about the risks they confront in their work, and then arming them with tools and proper incentives to help them confront those risks – is important to the success of an anti-corruption program. Corruption risk differs from country to country, and across functional areas of every organization. Engaging all areas of the company in implementation plans can increase chances of success.
Of course, regardless of the team's size or composition, the success of the team will depend on open and visible support from senior management. A company's CEO as well as high-level senior management should send the message that compliance is a shared responsibility across the company. They should empower the team with clear authority, adequate resources and the independence necessary to implement and enforce the program.
Corruption is an issue that continues to pose risks to reputation, resources, and the bottom line for companies. Taking a cross-functional approach to implementing an anti-corruption program will help to advance engagement by key stakeholders and ideally, turn policies into sound practices throughout an organization.