Review of ABC programme post debarment monitorship

For a global organisation, headquartered in the UK, GoodCorporation undertook a high-level desktop review of their Anti-Bribery and Corruption Policies and Procedures. The organisation had recently been under a three-year monitorship following bribery allegations, during which time it had up-graded its compliance programme extensively.

To ensure that the new programme was robust and would provide proper protection moving forward, the audit committee requested an independent audit of policies and procedures at group level. The programme was assessed against the GoodCorporation ABC Framework to identify any gaps and provide a score for each point.

Preliminary results were shown to the group compliance team with a full report presented to the audit committee. The report provided an overall assessment of the adequacy of the policies and implementation process, highlighting strengths and weaknesses, making recommendations for improvement and indicating where remedial actions are required to ensure best practice is in place.

The findings were then benchmarked to indicate effectiveness against the ABC programmes of other international organisations.

In this case GoodCorporation noted a fundamental change that occurred in the organisation's focus on ABC risks, with the most senior people taking a very active interest in the policies and procedures being implemented to address bribery and corruption risks. There were also leading edge approaches to embedding procedures into, for instance, sales activities.