OCEG Anti-Corruption Illustrated Series

Organizations must address global corruption challenges with a comprehensive

and dynamic program. To succeed, the board and management must demonstrate 2 DEVELOP THE PROGRAM PROGRAM OWNERS
and demand an anti-corruption culture. Design a comprehensive and balanced anti-corruption program that AN ANTI-CORRUPTION PROGRAM
corresponds to the risks identified during the assessment process. IS GOOD FOR BUSINESS
Establish policies, procedures and controls in all levels of the business,
Strong anti-corruption programs help
with owners for each. Obtain board and management endorsement
to build a climate of integrity and an
of strategies, short and long term expectations, and
RISK ethical culture across the extended
resources, with ongoing communication of this support. AUDIT
enterprise that drives desired conduct
1 START: ASSESS RISKS CORRUPTION IDENTIFICATION
AND
FINANCE
BUSINESS
COMPLIANCE OPERATIONS
and supports compliance overall.
OTHERS AND LEGAL Compliant companies perform better in

RISKS
Identify corruption risks considering factors
ESTABLISH PROGRAM the marketplace and have a competitive
including nature and location of business
OWNERSHIP AND OVERSIGHT advantage. An effective anti-corruption
activities, third party relationships, methods
OBJECTIVES program enables the company to:
for generating business, and applicable Anti-corruption efforts require coordinated
laws. Evaluate and rank risks based on the action involving many in the C-suite and
organization’s established risk appetite, and managers of operations that present
be prepared to respond to internal and corruption risk. A management commit-
external changes that affect the assessment. tee or internal stakeholder group can
FULFILL LEGAL OBLIGATIONS
ensure that necessary communication AND GUIDANCE
takes place, resources are committed,
REVIEW, REALIGN, • U.S. Foreign Corrupt Practices Act
7 AND REPORT and sufficient support for effective- • U.K. Bribery Act
ness of the program exists.
Take timely corrective and disciplinary action for POLICY DESIGN • U.S. Dodd-Frank and Patriot Acts
violation of the anti-corruption program. • Public Procurement Laws
M&A
Continually evaluate the program and adjust it THIRD PARTY and Regulations
to ensure alignment with changes in risk profile.
RELATIONSHIPS 3 • Guidance from OECD, World Bank,
Keep management and the board informed of PERFORM DUE DILIGENCE and Non-Governmental Organizations
Knowing how and where your vendors, agents and customers operate, and DEFINE AND
program outcomes and needs through regular IMPLEMENT • OCEG GRC Standards
understanding the activities and controls of any planned acquisition, as well as the risks
reporting. Strengthen assurance of program POLICIES • Contractual Obligations
they present, is an essential part of the anti-corruption program. Due diligence should
sufficiency with external review and certification. Write policies that map to
include analyzing whether established steps of an effective program are followed.
regulations, obligations and
P E R AT I O N S / S TA K
business processes. Establish
ESS O EHO
SIN LDE owners responsible to ensure
BU RS
SCREENING K EY continued appropriateness and
6 MONITOR AND EVALUATE AUDITING/ effectiveness. Communicate to
REINFORCE BRAND AND
Track and assess policies and controls for TESTING
ACCOUNTING/ key stakeholders including CORPORATE REPUTATION
effectiveness and performance in various ways: FINANCE
CONTROLS staff, third parties, auditors, • Enhance Brand Credibility
and customers. • Solidify Shareholder Trust
SCREEN SALES/ LOGISTICS/
monitor internal and external information MARKETING DISTRIBUTION/ • Gain Respect in the Marketplace
PURCHASING
and compare vendor, partner and customer
records against trusted data sources for red
flags that indicate issues INVESTIGATIONS
MANUFACTURING
4
BUILD AND
IDENTIFY HOTLINE OPERATE CONTROLS
establish hotline and other open channels for DATA
reporting and resolution of questions and issues Establish procedures and controls to
S
U RE prevent, detect, correct and mitigate ASSURE THE BOTTOM LINE
ED
INVESTIGATE OC • Protect Corporate Assets
PR the risks. Include process, technology,
obtain and assess information about observed PO and Operations
LIC human capital and physical controls.
or suspected misconduct, using appropriate IES • Enable Public Procurement
qualified teams, and considering privilege issues ANALYTICS Establish owners to monitor controls to ensure
effective workflow, continued appropriateness of Lines of Business
ANALYZE design, and operation in business units. Regularly • Enable Operation in
evaluate data to locate concerns and potential problems by document, assess and test controls. Corruption-Prone Countries
applying analytic techniques, tools and reporting capabilities • Prevent Revenue Loss From
Non-Compliance
AUDIT 5 TRAIN AND EDUCATE
provide regular internal audit oversight and inspection of the Develop and deliver training in various forms to raise stakeholder awareness and competence • Avoid or Reduce Fines
anti-corruption program; test and assess controls to determine regarding anti-corruption goals, policies, procedures and controls. Identify role-specific programs and Penalties
if additional or modified action is necessary with desired outcomes and develop content and delivery methods appropriate for each target
contact Scott L. Mitchell smitchell@oceg.org for comments, reprints or licensing requests audience, taking cultural and language issues into account. Assess, certify, and track training results. ©2012 Dachis Group
©2012 OCEG