Today, companies around the world face daily challenges associated with corruption. This risk coupled with new laws and heightened enforcement are just a few of the factors driving companies to implement and improve anti-corruption compliance programs. However, while intentions may be good, many companies still struggle with compliance.
In the new whitepaper, Why Anti-Corruption Programs Fail: Turning Policies into Practices , the Center for Responsible Enterprise And Trade (CREATe.org) outlines some key reasons why anti-corruption programs often fail and provides practical recommendations for companies to strengthen and improve anti-corruption practices, not only across an organization, but also with third parties.
Top challenges range from a failure to fully commit the human and financial resources to support a robust program; to a failure to understand and address the actual corruption risks faced by the company; to a lack of robust engagement on anti-corruption with employees and third parties; to developing what amounts to a 'paper program' by not embedding effective business processes across an organization, among others.
Senior leadership and 'tone at the top' is essential, and the compliance function should have independence, autonomy, resources and visible support from senior leadership. Middle management involvement is equally important for communicating about and setting an example of required behaviors.
Training is an area that is frequently targeted in enforcement actions as inadequate. One-size-fits-all packages should be replaced with training tailored to risks and responsibilities, and clearly communicating that compliance is the responsibility of all employees. Additionally, leading companies are increasingly training, monitoring and engaging with third parties on anti-corruption.
A broad range of additional internal controls should also be in place to ensure that business processes support policies. These range from monitoring to taking corrective actions to fill gaps in the program when issues arise, among other activities.
Even among companies for whom compliance has been a long-standing effort, it takes sustained commitment and energy to embed anti-corruption compliance into business practices and to ensure that they are continually improved to meet new risks associated with growth and expansion.
Click on the image below to start a slideshow of the most common mistakes organization's make in their compliance efforts.