“Companies have a responsibility to demonstrate their commitment towards preventing bribery as a matter of priority. It is necessary for them to identify potential incidents and to recognise them when they occur. However, many companies are ill-prepared,” said Rudi Kruger, General Manager at LexisNexis Risk Management.
First and foremost, it is important to note that bribery and corruption do not show up in plain sight. Companies are often unaware of their risk because they are not aware of the many forms in which bribery and corruption can occur. Although not all inclusive, the list of indicators goes a long way towards creating awareness on the many guises and opportunities for corruption to occur.
Be on the lookout for the following indicators when tackling potential bribery and corruption.
Abnormal cash payments
Abnormally high commission percentage being paid to a particular agency. This may be split into 2 accounts for the same agent often in different jurisdictions
Abusing decision process or delegated powers in specific cases
Agreeing contracts not favourable to the organisation either with terms or time period
Avoidance of independent checks on tendering or contracting processes
Bypassing normal tendering / contractors procedure
Company procedures or guidelines not being followed
Individual never takes time off even if ill, or holidays, or insists on dealing with specific contractors him/ herself
Invoices being agreed in excess of contract without reasonable cause
Lavish gifts being received
Making unexpected or illogical decisions accepting projects or contracts
Missing documents or records regarding meetings or decisions
Payments being made through 3rd party country, eg, goods or services supplied to country A but payment is being made, usually to shell company in country B
Pressure exerted for payments to be made urgently or ahead of schedule
Private meetings with public contractors or companies hoping to tender for contracts
Raising barriers around specific roles or departments which are key in the tendering / contracting process
Unexplained preference for certain contractors during tendering period
Unusually smooth process of cases where individual does not have the expected level of knowledge or expertise
The payment of, or making funds available for high value expenses or school fees etc on behalf of others.
In addition to these tell-tale signs, it’s in your organisation’s best interest to have in place comprehensive due diligence policies and procedures, which prove highly effective in mitigating risk as they provide you with the relevant intelligence.
All parties involved in your business, whether suppliers, partners, acquisition targets, contractors, resellers, grant applicants, other associates and in-house personnel, must be thoroughly vetted on an ongoing basis.