ANTI-BRIBERY AND CORRUPTION DURING COVID-19: SIX TIPS FOR

COMPLIANCE OFFICERS
COVID-19 has disrupted everything – supply chains, the market, how we work and how we
interact with each other. For compliance teams, flexibility and adaptation are key to ensuring that
you are on hand for your business to guarantee that it is making the best possible
decisions when under pressure.
The Business Integrity team at Transparency International UK has compiled some top tips to
ensure that you can keep your organisation running with integrity during this global crisis and
ensuring anti-bribery and corruption (ABAC) best practice.
1. ENSURE YOU HAVE A GOOD RISK-ASSESSMENT FRAMEWORK AND THAT
YOU ARE ACTIVELY USING IT AS YOUR BUSINESS CHANGES.
This is particularly important for organisations whose business models have changed
dramatically, such as those who have pivoted to support efforts to produce healthcare products or
whose supply chains have shifted dramatically from one region to another. New geographies and
new sectors bring new bribery and corruption risks and in many cases, additional regulations.
These must be assessed, understood and mitigated – even in these challenging times and even by
those businesses who genuinely want to support the effort to combat COVID-19.
Transparency International UK’s Diagnosing Bribery Risk is a detailed guide for business on
how to conduct a risk assessment and how to use it effectively to protect your business and
reduce risks of corruption. Our Global Anti-Bribery Guidance Portal (more on this in tip 4), has
also recently undergone a major revamp to ensure it continues to offer up-to-date summaries of
anti-bribery legislation. This includes information from jurisdictions across the globe, including
China, Brazil and Ukraine, to help businesses as they navigate new markets and their differing
legislative landscapes.
2. TONE FROM THE TOP HAS NEVER BEEN MORE IMPORTANT.
Make sure that your C-Suite are living and breathing integrity. Now more than ever, it is critical
that business leaders act with integrity and ensure that their employees are doing the same. They
can do this through regular communication with employees – perhaps a short video reminding
staff of the company’s values and ethics priorities.
If you are worried that your Senior Management team are not taking this seriously, we hope our
recent Open Business report will help. It sets out the business case as to why conducting
business ethically and reporting openly, particularly about ABAC issues, is critical to building
trust with customers, investors, your employees and the general public. All eyes are on
businesses right now – and reputations are at stake.
If you have people in your teams or in the wider organisation who have less to do in these
turbulent times, a useful exercise might be to review what the business is disclosing against the
principles set out in the report. The question we are challenging businesses to address is
‘why not disclose?’.
3. REVIEW YOUR LOBBYING PRACTICES TO ENSURE YOU HAVE ETHICAL
POLICIES AND PROCEDURES IN PLACE AND ENSURE YOU ARE OPEN ABOUT
WHAT YOU ARE LOBBYING FOR/AGAINST.
Most, if not all, businesses lobby government and this is a perfectly legitimate business activity –
when done responsibly. At this time of crisis, where government policy is being created and
implemented at pace and where markets and sectors are facing huge amounts of disruption, we
have already seen in many markets a huge upsurge in lobbying activity. At this time where lives
and livelihoods are dependent on the decisions made, it is all the more critical that businesses do
not exert undue influence over political decision-making. You can evaluate your lobbying
practice against our best practice using our 2018 Corporate Political Engagement Index.
4. CONSIDER CONDUCTING A SELF-ASSESSMENT OF YOUR COMPLIANCE
PROGRAMME TO ENSURE IT IS FIT-FOR-PURPOSE.
Budgets are tight across many businesses right now, meaning external monitoring and review of
programmes may be difficult to sign off. Many internal investigations and audits will be put on
hold too. Whilst this is not ideal, it presents an opportunity for your team to review the policies
and procedures that you do have in place and see whether your Compliance programme does
have ‘adequate procedures’. Transparency International UK offers a free-to-use Global Anti-
Bribery Guidance Portal. The Portal includes practical summaries of anti-bribery legislation from
jurisdictions around the globe and provides an 18-module set of guidance covering topics
including risk assessment, due diligence, managing third parties and aligning incentives to
behaviour.
For those who still have a modest budget, we also offer our Corporate Anti-Corruption
Benchmark that allows you to assess your company’s ABAC programmes against global legal
requirements and against our best practice – ensuring your company stays ahead of the game and
is able to effectively demonstrate adequate procedures. Not only that, but by participating, you
are supporting our mission to fight corruption. The 2020 Benchmark is launching on the 6 th April
this year and is still open for new participants.
5. WITH MANY OF YOUR SALES COLLEAGUES UNABLE TO TRAVEL, SEIZE
THIS OPPORTUNITY TO CONDUCT TRAINING ON ETHICS AND COMPLIANCE.
When the COVID-19 crisis is over, your sales and frontline colleagues will be back out there in
the market. Scheduling training – even short refreshers – is a good way to demonstrate your
company’s commitment to ethics at this time. Even if you don’t have training materials ready,
we have some free-to-use online training which you can use. It is also customizable for a small
cost. If you feel that you really want to seize this opportunity, we are still offering virtual face-to-
face training to support businesses.
6. REITERATE YOUR ETHICAL REQUIREMENTS – SUCH AS YOUR CODE OF
CONDUCT – TO YOUR SUPPLIERS AT THIS TIME AND KEEP TRACK OF HOW
YOUR SUPPLIERS’ RISKS PROFILES MAY BE CHANGING.
All businesses are under pressure at the moment, whether they are positively or negatively
impacted by COVID-19. Your suppliers and wider supply chain will also be feeling these effects
and will be making some difficult decision. You need to ensure that you manage those risks
effectively too. Third party management is always a high-risk area for business, but now more
than ever. We have a whole section of the Anti-Bribery Guidance Portal on managing suppliers
and contractors. Key things to consider are regular communication with your suppliers about
changing risks, conducting renewed due diligence and setting expectations of exercising audit
rights when possible again.