Our roadmap for Bribery Act compliance follows the Six Principles in the UK Government's Bribery Act Guidance. The first of these principles states that your procedures to prevent bribery should be proportionate to the bribery risks you face, which in turn is determined by the nature, size and complexity of your company. Bearing this in mind, your roadmap should include:
- Step 1: Prepare anti-bribery policies procedures and ensure that they are communicated to and attested to by employees and associated persons. Depending on your risk assessment these may include gift & hospitality, donations, charitable contributions, facilitation payments, dealing with public officials.
- Step 2: Train your employees and associated persons to identify, avoid, resist and report bribery. The training should include practical scenarios that are relevant to your business.
- Step 3: Implement a Gifts & Hospitality Register (GHR) to address the most common channel for actual and perceived cases of bribery.
- Step 4: Offer an anonymous whistleblowing register that your staff and use to report suspicions of wrongdoing internally or external sources.
- Step 5: Obtain compliance declarations from your third-party associated person to ensure that your supply chain is aligned with your internal anti-bribery standards.
- Step 6: Conduct anonymous staff surveys to uncover deficiencies in your internal controls and external threats, which should inform the continuing improvement of your anti-bribery policies and procedures.
Corporate policies are the backbone of any successful business. They guide conduct and behaviour and set out the types of behaviour a firm expects of its employees.
They are the mechanism for translating external regulatory requirements into the DNA of a firm - compliance is ensured when employees understand and operate within the policy boundaries.
With Skillcast's online Policy Hub your employees can regularly review and attest all the relevant policies in a timely and efficient manner, and you can evidence to regulators and authorities when required.
Most UK businesses have adopted anti-bribery policies - but it’s the way they are implemented that makes a difference.
Your staff need to understand your company's rules and expectations in relation to gifts, hospitality, donations, sponsorships etc. Those in higher-risk positions may need further training, on issues specific to your company.
Principle 5 of the UK Government's Bribery Act Guidance states that "Effective training is
continuous, and regularly monitored and evaluated."
However, the repeated training that's required to comply can cause staff fatigue. Therefore, we provide an array of anti-bribery courses to help you keep your staff aware and engaged on this risk:
Gifts & Hospitality Registers
Gifts and hospitality are widely recognised as a source of bribery risk. They can be used as outright bribes on their own or as a way of obliging/entrapping a person.
The UK Government's Bribery Act Guidance recommends that bribery prevention procedures should include "gifts, hospitality and promotional expenditure, charitable and political donations, and demands for facilitation payments."
This requires you to establish policies clearly outlining your company's rules, limits and procedures. In addition, depending on the nature of your business and risk assessment, you may also want to implement a Gifts and Hospitality Register to record and approve staff requests for giving and receiving gifts, hospitality, sponsorships, etc.
With the Skillcast online Gifts and Hospitality Register you can run this workflow efficiently and analyse the data over time to ensure compliance with the requirements of the Bribery Act.
Blowing the whistle about internal and external malpractices is vital for the functioning and survival of companies.
Whistleblowing is the process by which employees can report suspected or actual improper conduct. It is done in confidence or anonymously, which is vital as staff may feel unsafe or unable to report such behaviour to management.
A solution is to create an online whistleblowing register, enabling your employees to report any suspicion or knowledge of bribery breaches anonymously.
Third-party Due Diligence
You may need third parties to complete disclosures or declarations regarding compliance with bribery laws, regulations or internal standards.
Using email of paper-based processes is slow, inefficient and creates unnecessary duplication.
Using our online compliance declarations will help you to streamline the collection, analysis and management of due diligence for associated persons outside your organisation.
Your employees and managers are your first line of defence against bribery risks, and their knowledge about the effectiveness of your compliance procedures and the nature of external threats is invaluable.
Principle 3 of The UK Government's Bribery Act Guidance requires companies to assesses their bribery risks. Such surveys can uncover "(i) deficiencies in employee training, skills and knowledge, (ii) incentives for excessive risk-taking, (iii) lack of clarity in policies/procedures for gifts, hospitality charitable etc, (iv) lack of clear financial controls."
Further on, Principle 6 reiterates that "Staff surveys and questionnaires provide an important source of information on the effectiveness and a means by which employees and other associated persons can inform the continuing improvement of anti-bribery policies."
Skillcast Compliance Survey Tool can help you to conduct robust, anonymous staff surveys that ensure the widest coverage and enable employees to feedback to you in confidence.
Free Anti-bribery Resources
We have 60+ free compliance training aids, including assessments, best practice guides, checklists, desk-aids, eBooks, games, handouts, posters, training presentations and even e-learning modules.
Anti-bribery Training Presentation
Our free interactive training presentation will enable you to give a time-efficient presentation to your staff.
Teach your team about UK Anti-Bribery laws and red flags they should be wary of to ensure they don't become complicit or victims of this crime.
Anti-bribery Good Practice Guide
Our simple good practice guide will help your employees learn anti-bribery good practices and avoid bad ones. Familiarise yourself and your colleagues with anti-bribery regulations by outlining examples of good and bad practices provided by the Financial Conduct Authority (FCA).
Anti-bribery E-learning Module
Transparency International UK has partnered with Skillcast to produce the gold standard of anti-bribery training - 'Doing Business Without Bribery'.
It provides comprehensive anti-corruption training for front-line staff. It will help you to prevent and resist bribery more effectively and comply with the UK Bribery Act.
Gifts & Hospitality Checklist
Often it's tricky knowing where bribery starts and goodwill ends.
We have created a handy checklist in PDF and editable Word formats. It contains 10 tips to help your team feel more confident when dealing with gifts.
Best Practices in Bribery & Corruption
If you'd like to stay up to date with bribery best practices, industry insights and key trends across regulatory compliance, digital learning, EdTech and RegTech news subscribe to Skillcast Compliance Bulletin.
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