The Tribune

By DEREK SMITH

Bribery and corruption are pervasive risks that undermine governance, distort market fairness and erode public trust in businesses. Establishing a robust anti-bribery and corruption culture is not merely a regulatory requirement in many jurisdictions but a strategic imperative for safeguarding a company’s reputation and ensuring long-term sustainability.

This article will provide a road map for building and sustaining an effective anti-bribery and corruption culture.

Leadership commitment and tone at the top

The foundation of an anti-bribery and corruption culture is leadership commitment. A zero tolerance stance against corruption and bribery must be communicated unequivocally by senior executives and Board members. More than just a symbol, this entails:

* Public declarations of commitment

* Active participation in compliance initiatives

* Keeping senior management and directors as accountable as their employees

Establishing comprehensive policies

Anti-bribery and corruption policies must be robust. Prohibited activities, reporting procedures and disciplinary actions for non-compliance should be outlined. Effective policies include:

* Clear definitions of bribery and corruption

* Detailed gift, entertainment and donation policies

* Explicit rules on facilitation payments

Organisations such as Transparency International recommend using ISO 37001 (Anti-Bribery Management Systems) to guide the development of a structured approach to anti-bribery and corruption.

Training and Awareness

Employees and stakeholders benefit from training on risk management, responsibilities and reporting mechanisms. High-impact training programmes include:

* Role-specific training tailored to higher risk roles such as procurement or sales

* Real world scenarios and case studies to illustrate the consequences of non-compliance

* Ongoing education reinforced through refreshers and e-learning modules.

For example, gamified training modules engage employees and effectively reinforce compliance knowledge. Forbes’ article, ‘The what and why of gamification In employee training’, said: “When a company gamifies employee training, it leverages technology in much more enjoyable, interactive and fun ways.” The article further explained: “It makes it easier for workers to learn new technologies, processes and ways of doing things in a world that continuously uses the power of technology to exponentially increase productivity.”

Implementing strong internal controls

Robust internal controls detect and prevent corrupt practices. Key measures include:

* Conducting thorough due diligence on third-party vendors, consultants and partners

* Establishing clear segregation of duties to prevent conflicts of interest

* Maintaining meticulous records of financial transactions

Fostering a speak-up culture

The importance of encouraging employees to report unethical behaviour cannot be overstated. An anonymous reporting channel, such as a hotline or online platform, ensures confidentiality and protection against retaliation. In companies with whistleblower mechanisms, fraud and corruption can be detected and mitigated more effectively.

According to an Association of Certified Fraud Examiners (ACFE) study, 43 percent of fraud cases are discovered through employee tips.

Regular monitoring and auditing

Regular audits and continuous monitoring identify vulnerabilities and ensure compliance with anti-bribery and corruption policies. Proactive companies:

* Conduct periodic risk assessments to adapt policies to emerging threats

* Engage external experts to validate the effectiveness of internal controls

* Monitor high-risk activities such as international operations or government interactions

Accountability and discipline

Consistent enforcement is the key to an anti-bribery and corruption culture. Regardless of rank, employees and executives must be held accountable for violations. Companies must communicate disciplinary actions publicly to reinforce their commitment to anti-bribery and corruption principles.

In short, it takes strategic leadership, effective policies and engaged employees to build an anti-bribery and corruption culture. The integration of these best practices can both ensure compliance with global standards and foster trust among stakeholders, creating an ethical and sustainable business environment.

• NB: About Derek Smith Jr

Derek Smith Jr. has been a governance, risk and compliance professional for more than 20 years with a leadership, innovation and mentorship record. He is the author of ‘The Compliance Blueprint’. Mr Smith is a certified anti-money laundering specialist (CAMS) and the assistant vice-president, compliance and money laundering reporting officer for CG Atlantic’s family of companies (member of Coralisle Group Ltd) for The Bahamas, St Vincent & The Grenadines, St Lucia and Curaçao.