Bribery is a huge problem in the workplace. According to the World Bank, £800 billion is paid each year in bribes, with this activity resulting in considerable corruption and enforcement activity.
The UK Bribery Act 2010 was introduced to clamp down on illicit payments, while the National Crime Agency was established in 2013 to oversee law enforcement response.
A crucial component of the Act is that it’s not just individuals who can be held accountable for taking or offering bribes. Their employer can also be fined up to 10% of their organisation’s turnover, and they could be prohibited from tendering certain contracts.
It’s therefore essential that organisations take appropriate steps to prevent bribery and corruption in the workplace. In this blog, we look at seven ways that you can get started.
1. Implement an anti-bribery and anti-corruption policy
The first step to preventing bribery and corruption in the workplace is to create an organisational policy that establishes the rules.
Under UK law, it’s illegal to offer, promise, give, request, agree, receive or accept bribes. This should be clearly stated within your policy, along with the consequences of being caught partaking in bribery.
UK government guidelines also recommend that an ABAC (anti-bribery and anti-corruption) policy outlines your organisation’s approach to reducing and controlling the risks of bribery.
2. Establish a culture of ABAC
You should complement your ABAC policies with a series of activities that promote ethical behaviours in the workplace.
Everyone in the organisation, from the board of directors and business owners to the compliance team, must make it clear that bribery and corruption will not be tolerated.
This can be achieved by conducting presentations, sending email reminders, and performing other awareness campaigns. For example, you might post a message on the company intranet or put up posters in the office.
3. Conduct third-party due diligence
ABAC laws also apply to an organisation’s third parties, including agents, intermediaries, consultants and associates.
If any business that acts on your organisation’s behalf is found guilty of corruption or bribery, you can be held liable. As such, you must conduct due diligence on these parties and implement appropriate assessments.
This means checking that the third party is who they claim to be, that they have appropriate credentials and that they are approved at senior management level.
4. Know the difference between bribes and gifts
Under UK law, bribery doesn’t only include favours that are performed in exchange for money. It can include any advantage that’s offered in return for a favourable action or decision.
This clarity is essential, because it establishes the bribes can come in any form, including gifts or quid pro quo scenarios. In other words, suggesting that if the person is rewarded now, they will be given certain benefits.
Most employees understand that cash bribes are not to be tolerated, but they might not be aware that it is equally illegal to receive other forms of gifts or favours.
They might not also understand the difference between a bribe and a gift. It’s perfectly legal for someone to send an employee, a bottle of wine or tickets to a show, for example, as long as there is no suggestion that the recipient should do something in return.
5. Understand how ABAC works in everyday practices
It’s easy to fall into the trap of thinking of bribery as a concept rather than a real-life risk.
Part of the problem is that the practice of offering and receiving bribes is rarely signposted; payments are almost never explicitly referred to as bribes. They might instead be offered using a euphemism, such as ‘facilitation payments’.
If organisations are to protect their staff from corruption and bribery, they must make it clear that the threat is real and isn’t always in plain sight.
6. Know the signs of bribery
As we’ve established, it’s not always clear when someone is offering a bribe. The proposal is usually cloaked in ambiguous language or is made to seem like an official process.
Bribery can often be seen in the form of payment requests when someone has facilitated a deal but has offered no other services. It might not seem like it, but you’re giving them a bribe.
Other indicators of bribery are when you are asked to meet without company representatives present, or when you are asked to make advanced or cash payment – particularly if those payments are to third parties.
7. Provide regular anti-bribery training
The tips we’ve discussed in this article should be collated and delivered repeatedly to ensure that everyone in the organisation understands and remembers the lessons you are providing.
This is where anti-bribery staff awareness training is essential. Guidance doesn’t only help people avoid illegal practices. It should also establish a workplace culture where people act conscientiously and recognise inappropriate behaviour.
Regular training ensures that staff understand their legal requirements and their employer’s responsibilities, keeping the risks related to bribery at the forefront of their minds.
You can get your training programme started with GRC eLearning’s Anti-Bribery Staff Awareness E-learning Course.
This online course explains what exactly bribery is and how it affects organisations. It’s designed by experts to help organisations build a risk-based approach to mitigate the threat of bribery.
It also demonstrates how you should respond if you are offered a bribe, and what you should do if you discover someone in the organisation has accepted one.