Anti-bribery and corruption

Are you doing enough to protect your organisation?

Answer 5 questions to see if your organisation meets the gold standard of managing bribery and corruption.

Start the assessment

Introduction

In recent times, arrests of individuals on corruption charges which have been highly publicised in Australian media, along with the Royal Commission into Trade Union Governance and Corruption, are forcing companies to consider what they can do proactively to avoid being blindsided by a corruption incident.

Organisations continue to be caught out, and the financial and reputational impact is becoming more significant. Each incident can taint not only the individuals involved but an entire organisation, sometimes long into the future.

Although risk profiles vary based on industry and operations, there are some common measures organisations can implement that are proportionate to the bribery and corruption risks they face. The following five questions are designed to provide you with a high level snapshot of your organisation’s defences.

Tone from the top

Are your Board and senior executives involved in, and committed to, combating bribery and corruption?

Yes
No

Culture

Which statement most accurately represents your organisation’s approach to influencing corporate culture regarding bribery and corruption?

  • We deliver annual training which addresses both personal obligations and our organisational approach to managing bribery and corruption risks. We publish periodic communications regarding the issue, and our employees are highly aware of policy and procedures used to address concerns that may arise.
  • Ethical behaviour is addressed as part of the Code of Conduct during induction training. Organisation policies are accessible via our intranet and our employees are broadly aware of them.
  • All our employees sign an employment contract which articulates their obligations regarding the Code of Conduct.

Risk assessment

When was the last time your organisation assessed the nature and extent of internal and external bribery and corruption risks, and the effectiveness of controls used to combat them in higher risk areas?

In the past 12 months In the past 24 months I couldn’t tell you...

Due diligence

Do you have a specialised due diligence program to screen third party suppliers and joint venture partners for potential red flags?

Yes
No

Monitoring and review

Which of the following tools does your organisation use to detect and respond to potential bribery and corruption issues? (select all appropriate)

  • Bribery and corruption framework, including standalone policy
  • Key risk indicators included in performance metrics for senior staff
  • Integrity focussed data analytics
  • Whistleblower hotline
  • Electronic gift and conflicts of interest registers
  • Regular testing of preventative controls for effectiveness
  • Formalised triage process and escalation procedure for incidents
  • Dedicated and appropriately skilled investigations staff
  • Bribery and corruption as standing item in Board reporting
  • Post investigation learnings used to improve policies and processes

Gold
standard
Silver
standard
Bronze
standard

Contact us for a detailed diagnosis on how effective your organisation is at preventing bribery and corruption

Malcolm Shackell

Sydney
02 8266 2993
malcolm.shackell@au.pwc.com

Mark Rigby

Sydney
02 8266 1774
mark.rigby@au.pwc.com