Anti-Bribery and Corruption Training

Written by Dave Robson on Thursday May 18, 2017

In order to achieve good understanding of, and compliance with, your anti-corruption policies, you need a process that transfers the necessary knowledge, insight and skill to those who serve your organisation.

This means that an active and wide-reaching training programme is an essential component of your anti-corruption compliance programme.

The approach you take to your anti-corruption training programme should achieve the dual objectives of achieving genuine buy-in and adherence while meeting the requirement of having evidence that the training has been delivered and received. 

In this short article we will outline some of the considerations when conceptualising an anti-corruption training programme, following a simple who, what, when, how approach.

Who? Training needs to be given to all, at every level in the organisation, with the most senior and junior levels being no exception. It is important not to make the assumption that new board members understand their governance obligations or that entry-level workers will not be faced with ethical dilemmas. Training should also be provided to all who act on your behalf, such as agents, representatives or intermediaries. You will need a process for communicating your anti-bribery and corruption policies and procedures to your suppliers and customers, whose support and adherence you will require. Where suppliers do not have their own anti-corruption training programme you need to consider assisting them in this regard. 

What? Training should at a minimum cover the content of anti-corruption policies and procedures including those for reporting suspected wrongdoing. Managers and supervisors need to understand their role in supporting the development of a compliance culture and appropriate ethical tone. The ability to undertake risk assessments and to recognise red flags is needed throughout the organisation, and can be tailored to the needs of different roles such as those in marketing, procurement, financial accounting and the like. Scenario-based training that provides practice in anticipating and responding to ethical dilemmas and bribery situations should be considered, especially for those most likely to face them. As you need evidence of both the delivery and receipt of guidance on the organisation’s anti-corruption policies, signed policy acceptance declarations and attendance registers are essential. 

When? At key entry points and on an ongoing basis. Training should be provided as a compulsory component of new employee induction, and this induction need should be revisited whenever an existing employee is promoted into a new position with changed challenges and expectations. Regular, varied and ongoing input that keeps anti-corruption awareness at top of mind is necessary. A risk-based approach that sees more frequent training for those identified as highly-exposed is expected.

How? The range of training-delivery methods available has never been greater, and it is now possible to reach large numbers of people across multiple and remote sites using digital education tools such as on-demand webinars. Ideally you will incorporate a variety of approaches:

• Tick-box methods: Much-maligned when used in isolation to pay lip service to the training requirement, the “tick box” approach in which employees are required to acknowledge receipt of information about company policies, so providing a documented audit trail, remains an efficient way of disseminating knowledge. Always remember though that your task is not only to transfer information and responsibility but to transform attitudes.
• Flip the classroom: Use multiple methods that favour the self-study of learning material and the use the valuable “classroom” or meeting room time for group discussion, debate and questions.
• Just in time: Learning opportunities should be accessible to employees when and where they need them, for example, having on-demand access to guidance on handling demands for facilitation payments at customs and border posts when these are most likely to be encountered. Another example would be reminders about the company’s gift-giving and accepting policy ahead of occasions when these are traditionally exchanged.
• Micro-learning: Small chunks of input play an effective role in building awareness and skills. These can be made available on a regular basis through the organisation’s various employee communication vehicles.
• Contracts, briefings, stationery and marketing material: While simultaneously reinforcing employee awareness, anti-corruption policies and expectations can be communicated to suppliers as part of contractual arrangements and at supplier briefings. They can also be promoted to customers, for example in marketing material and on the organisation’s website.  

Regular reinforcement of anti-corruption compliance messages can yield great results and maintain strong levels of engagement.

The above approaches are not exhaustive and must of course be tailored for your organisation – but hopefully provide some useful insight into ways to approach and embed this emotive subject matter.