Key steps to building an effective anti-corruption training programme

Over the last decade, legislators have been placing increasing demands on companies to build robust procedures to combat corruption, with potentially severe consequences for those that fail to respond. In our experience, companies that are struggling with anti-corruption compliance are often struggling with the more fundamental question of how to properly embed policies and procedures into the business.

According to GoodCorporation’s benchmark, based on over 100 anti-bribery and corruption (ABC) assessments conducted internationally, almost 30 per cent of the procedures assessed for training employees on ABC policies were found to be inadequate. Anti-corruption training for third parties such as sales agents and joint venture parties was even worse, with over half the procedures deemed inadequate.

To help businesses tackle this and ensure that adequate procedures to prevent corruption are firmly in place, GoodCorporation offers a range of ABC training programmes and courses drawing on our knowledge and expertise of building and evaluating effective anti-corruption compliance programmes.

Why is effective anti-corruption training important?

Regulatory authorities agree that effective communication and training deters bribery. Indeed, many authorities require companies to offer specific training programmes for executives and employees most exposed to corruption risks. The most recent guidance on the Foreign Corrupt Practices Act calls for businesses to “foster a culture of ethics and compliance with the law at all levels of the company”. By raising awareness of the risks and consequences of bribery, an organisation can make its expectations of conduct explicit and reinforce its zero-tolerance approach.

The first step in developing an effective anti-corruption training programme is to identify where the organisation is most at risk. This will ensure that appropriate resources can be allocated to develop targeted training programmes for the more high-risk parts of the business such as procurement, sales and marketing or government affairs. 

When developing an anti-corruption training programme, GoodCorporation often starts with a workshop for senior executives across the different business functions that are most at risk from corruption. Conducted at group or local level as required, an ABC training workshop will facilitate a deeper understanding of the organisation’s potential exposure to corruption and help the company identify and prioritise its training needs. Such workshops can help an organisation manage its risks effectively while also ensuring that collective ownership is developed for managing and embedding best practice. 

What should anti-corruption training include?

The best training programmes ensure that all the basic definitions and policy requirements are clear and properly explained. This should start with an explanation of bribery and improper influence and include other related issues such as conflicts of interest, facilitation payments and gifts and hospitality.

It is also helpful to summarise the legal requirements and the consequences for individuals as well as the organisation of failing to comply. For some organisations, this may mean explaining the legal requirements across different jurisdictions making it important to develop your training programme with subject matter experts who understand these varying global requirements.

To make the training both relevant and effective, make it clear where bribery is most likely to occur and include ‘real life’ scenarios, ideally tailored to the organisation, so that stakeholders develop a deep understanding of the potential risks and how to avoid them. Using subject matter experts to draft content and develop such scenarios will help build a training programme that promotes engagement and is relevant to the specific risks a business might face.

Make sure that the organisation’s own internal rules and processes are fully explained. This is particularly important for areas such as gifts and hospitality and conflicts of interest. The training should also remind stakeholders where the relevant policies can be found, and who to contact should they require more information.

Lastly, speak-up; when it comes to corruption, silence is never golden. Encouraging speak-up is an essential component of any anti-bribery programme. An ABC training programme should include details of the company’s speak-up or whistleblowing line as well as reminder of the internal system for raising concerns with line managers or other senior leaders.

What form of anti-corruption training is most effective?

While much has been written about the pros and cons of online or face-to-face training, the key element of an effective ABC training programme is to ensure it is appropriate and relevant to the culture of the organisation. Whatever form of training is developed, it should incorporate questions and answers as this promotes engagement, raises awareness and deepens understanding of the critical issues.

If budgets allow, face-to-face training can be the most effective. In person training often allows for critical issues to be explored in-depth, promoting greater interaction among participants. It also allows the organisation to gauge the levels of understanding and identify what works well and what could be improved for the future.

For large, international organisations ABC training webinars are particularly effective. Webinars can be developed to incorporate interactive break-out sessions, Q&As and scenario-based learning, all tailored to the needs and risk profile of the organisation. These should be conducted in the appropriate language and tailored to incorporate local issues.

For many organisations, however, in-person training across the whole organisation may be inappropriate, unaffordable, or possibly both. If this is the case, online anti-corruption training can be carefully developed enabling the organisation to deploy its main anti-bribery messages widely and meet its compliance obligations. E-Learning can also be particularly effective for training sales agents and intermediaries whose relationship to the organisation may need to be managed sensitively.

Who needs anti-corruption training?

One of the first principles to understand when embarking on an ABC training programme is that it may not be necessary to train everyone to the same extent. As the Ministry of Justice Guidance on the Bribery Act states, an anti-corruption training programme should be proportionate to the risks faced. In some jurisdictions such as France, it is a requirement to identify those most susceptible to risk as part of the mandatory anti-corruption risk assessment. Ideally a company would identify those most exposed and ensure that they, along with the senior management team receive the most detailed, high-level training.

There is, however, a minimum requirement to ensure stakeholders (staff?) that all are aware of the organisation’s anti-bribery policy and what is expected. In some cases, this may be covered through the code of conduct and can be included as part of any code of conduct training.

How often should anti-corruption training be conducted?

Best practice suggests that anti-bribery training is conducted annually, however rather than simply repeating the same training programme each year, the most effective anti-corruption training will build on previous years, focusing on specific issues as needs arise to deepen awareness and understanding. GoodCorporation also recommends that anti-bribery training is offered as part of new staff inductions and also to new suppliers and contractors where there is a risk of corruption.

Companies should also consider updating and re-running training in response to any incidence of corruption.

How to tell if anti-bribery training is working?

One of the obvious ways of assessing the effectiveness of an anti-corruption training programme is to monitor the incidents of bribery. However, it is too simplistic to conclude that if there is no bribery, the training must be working, so nothing further needs to be done.

Critical to having adequate procedures to prevent corruption in place is a thorough programme of monitoring and policy review. Best practice recommends regular internal and external reviews of practice and procedures which can check how well the policies are embedded and working on the ground. Such reviews form part of GoodCorporation’s anti-corruption services which support our clients in the building of robust anti-corruption programmes.

It is also best practice to monitor who has completed the training to ensure there are no gaps among the relevant stakeholders. Some companies also run refresher courses or test staff knowledge through surveys. This would be particularly beneficial in those business functions most exposed to the risk of corruption. For those individuals in the organisation most exposed to risk, it may also be beneficial to include awareness of the ABC programme in the appraisal process.

Reinforcing ABC training

Good communication is a key ingredient of an effective anti-corruption training programme. In addition to training sessions, be they online or face-to-face, an organisation should ensure that its anti-bribery policy and principles are widely disseminated, including on the company website, intranet and other communication channels. Bribery risks should also be discussed periodically at staff meetings with a reminder of the correct policies and procedures to follow. 

Increasingly companies are also developing apps to deploy policies such as the code of conduct or ABC. For  large organisations with a widely dispersed workforce as, this approach enables all staff to access resources online, including non-mandatory training.

The internal communications team can be enlisted to include regular and relevant messages to promote the company’s anti-bribery policies as part of the overall communications programme. This helps keep the policy front of mind and ensures that the required practices and procedures are properly embedded. 

ABC training for third parties

Managing the corruption risk in third parties remains one of the hardest areas for businesses to get right. It is also the area where organisations are most at risk, with the majority of prosecutions for bribery resulting from corrupt activities in the supply chain. 

In some high-risk sectors, it is becoming increasingly common to offer anti-bribery training for some of the most exposed suppliers. This is where e-learning can be particularly effective as it is easy to deploy and levels of engagement can be checked. At the very least, all suppliers should receive the company’s ABC policies during the tender process and best practice recommends that ABC clauses are also included in the contract. Suppliers should also have details of any confidential reporting lines and guidance on expected best practice.

Sales agents can also present a bribery risk, particularly in certain sectors and jurisdictions, consequently it is important to ensure that these agents are included in all relevant ABC training.

The benefit of effective anti-corruption training

Failing to prevent bribery can lead to lasting damage, not just to organisations but to individuals and the communities in which they operate. With regulators around the world intensifying their efforts to compel organisations to implement effective anti-bribery programmes, ensuring that the relevant policies and procedure are firmly embedded is essential. This requires the allocation of resources to ensure that appropriate and proportionate training is offered across the organisation. Not only will this help mitigate any risk from bribery, it also demonstrates an organisation’s commitment to a no-bribery regime. A commitment that investors as well as regulators and indeed society at large are also seeking.

GoodCorporation’s anti-corruption training programmes

GoodCorporation offers a range of anti-corruption training programmes including face-to-face training, e-learning, workshops and webinars, all tailored to the needs of individual organisations. Our programmes are designed by subject matter experts, drawing on our extensive experience of building and evaluating anti-corruption programmes across multiple sectors and international jurisdictions.

We also help devise clear communication programmes designed to reinforce an organisation’s zero-tolerance approach to corruption and ensure compliance with anti-corruption legislation. 

This combination of appropriate training supported by good communication is critical to developing an effective anti-corruption programme.