15 May 2020

Bribery & Corruption: Risk Management in Crisis Mode

It’s clear that during the recent months business and businesses have changed. So as we start to edge back to a new ‘business as normal’ and we evolve the way that we operate, it’s vital to ensure our organisation’s anti-bribery risk management process remains fit for purpose.

Why does it matter?

In many respects the pandemic has created a perfect storm for those out to secure an advantage. Organisations such as Transparency International UK warn against increased risks of fraud and bribery at this time, and the Serious Fraud Office remains very much open for business. There is unlikely to be much dispensation for a business failing to maintain adequate procedures, even in these circumstances.

Have the risks changed?

Every change to your organisation impacts on its risk profile for anti-bribery purposes. The effects of changes to products/services, supply chains and working arrangements are obvious but other less obvious factors, such as employee attitudes and changing market pressures, must also be considered.

For example hospitality may currently be postponed, and therefore the potential risk of suppliers or employees offering hospitality in order to gain preferential treatment from customers, is lowered, while on the other hand as more business is conducted remotely, visibility on how contracts are being secured is reduced, thus increasing risk of foul play. With that taking place in an environment where businesses are competing for survival, or employees are fearing redundancy, a new dimension of risk is added.

What do I need to do?

Even the most ‘risk-robust’ business would be well advised to review its existing anti-bribery provision against the new landscape, but there are small steps that every business can take:

  • Circulate existing anti-bribery & corruption policies and procedures;
  • Ensure training has been completed;
  • Check that your staff have appropriate IT permissions for invoice and commission approvals, stock records and due diligence;
  • Reinforce processes for payments, due diligence, sign off of contracts etc;
  • Don’t compromise on the fundamentals such as verifying documents received electronically, or carrying out ‘spot checks’ on financial transactions;
  • Monitor for ‘red flags’ such as employees talking of financial pressures or the job loss of a spouse or partner; and
  • Monitor commission or third party payments for ‘spikes’ or unusual patterns.

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About the Author
Clare Murphy, Partner

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