Your employees can form a vital line of defence against corruption, but only if they know what to look out for and how to respond appropriately. The insidious nature of corruption often means that employees themselves become unwitting facilitators.
If you consider a scenario of a foreign third party agent who pays a bribe to advance your business e.g. a bribe to a port official in return for overlooking inadequacy in customs documentation, the agent in that scenario is most unlikely to absorb the cost of that bribe, it will ultimately be paid by your organisation. An unsuspecting back office employee will process an invoice for that agent and the bribe will be reimbursed.
To adequately prevent bribery and to ensure training on anti-corruption policies and procedures is effective your employees should be trained to identify the ways in which corruption can be hidden, funded and facilitated. Corruption indicators, also known as “red flags”, are numerous and those who use corrupt methods are constantly devising new ways to continue their corrupt practices without detection. Such training is particularly useful for employees in countries where corruption is less common and team members might be more naïve about corruption risks.
By way of example, here are some red flags that would be relevant to your accounts payable team:
- Euphemistic or poor descriptions of services in invoices e.g. “special handling fee” or “miscellaneous fee”.
- You are in country ‘A’. Your agent is providing services in country ‘B’, but requests payments be made to an account in country ‘C’.
- Requests for payments to be made to shell companies or to numbered bank accounts.
- Requests for abnormally high commission payments.
- Pressure for payments to be made, before services are provided.
You should consider red flag training for all relevant departments, in particular finance and accounts, sales and marketing, tendering and contracts and any employee dealing with third parties that provide services for your organisation.
If you are unfamiliar with corruption risks and needs some tips on what to look out for, you could start by taking a look at the non-exhaustive list of corruption indicators that can be found on the SFO website.