The Bribery Act is finally coming into force ? have you taken steps to ensure your business is prepared?John Smart, head of the fraud investigation and disputes services team at Ernst & Young, says that businesses need to make an active effort to demonstrate their willingness to abide by the Bribery Act. “While the Bribery Act was originally delayed, it is now coming into force. It is urgent that companies look at their internal processes and take the right steps, before it’s too late.” The company’s recent European Fraud Survey shows that one in seven employees at large UK companies are prepared to offer cash payments to secure business, and little more than half are aware of an anti-bribery policy at their firm. Ernst & Young there recommends the following urgent steps that need to be taken in order to be compliant with the Bribery Act:
- Get your processes right. Businesses should appoint an ethics officer and undertake a risk assessment to give that officer a clear picture to work from. It’s very important to record incidents where ethical standards may have been breached, keep records and log any concerns.
- Know exactly what is going on in your company, especially if you operate in countries where corruption is common. It could be a shrewd move to employ a risk assessment adviser to examine your overseas operations.
- Working out what you can and can?t offer to clients can be difficult ? you are required to judge whether or not a gift or corporate entertainment counts as ?appropriate?. What is lavish to one may be seen as stingy by another. For instance, it might be acceptable to take a top broker out for lunch, but not to fly him out to New York in first class.
- Train your employees ? make sure they understand the Bribery Act by giving adequate support and guidance. Keep hold of any materials used, to show that you?ve taken training seriously. Again, this is particularly important given that in our recent survey, in which 74 per cent of respondents said that they had not yet received any anti-bribery training.
- Demonstrate the message of zero tolerance. As a first step, discuss the issues at a board meeting and ensure the minutes reflect that you have added anti-bribery measures to your code of conduct.
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