While every firm is unique and has its own corporate culture, the anti corruption compliance culture should be the same across firms. Strong leadership that is committed to carrying out business in an ethical, legally compliant and honest manner is an element vital to compliance culture. Such leadership walks away from businesses not meeting these standards.
A compliance culture is built over a period by developing effective controls and standards, which include risk-based procedures and policies that are followed and enforced diligently, senior management frequently communicating on the value and significance of ethical business practices and anti-corruption law compliance, regular training of the staff and stakeholders who matter, and continuous auditing and monitoring to confirm strict compliance.
Any company can develop such a culture, irrespective of its industry, location or size. However, it’s vital how committed its leadership is and the readiness to devote resources and sustained effort over a period to carry out business in an ethical and lawful manner, even if that means losing sales.
Senior Management Commitment
The senior management of a firm should set up a compliance culture. If the senior management is truly committed to corruption avoidance and prevention, the personnel and middle management throughout the firm would pay attention to probable corruption risks and would seek measures to avoid them.
Another key element to build a “compliance culture” is keeping effective controls and standards in place, which includes procedures and policies that have been devised to address risks the firm has in the actual world. A committed senior management would ensure these are diligently implemented, enforced and followed. This ensures all stakeholders that are aware of the organization’s requirements get drawn into a compliance circle through their involvement.
Another element that’s key to build “compliance culture” entails frequent senior management communications that remind the employees of the company that they must personally be attached to the firm’s zero non-compliance tolerance.
Regular Compliance Training
Another element vital for building compliance culture is systematic anti-corruption compliance training. Such training should be at least conducted once every year for all staff involved in global business or who could be in contact with international government officials. Such training can be conducted online, with targeted and live training for personnel in high-risk zones, such as international business development. A firm’s sales representatives, international consultants, resellers, offset brokers and distributors can also be provided live ethics training annually.
Continuous Monitoring and Auditing
Continuous anti-corruption compliance monitoring and auditing ensure that a firm’s standards and internal controls system are properly implemented, enforced and followed. Any issues or problems identified should be addressed promptly. Without such auditing and monitoring, there is no guarantee that the compliance initiative would work and its requirements will be met by third parties.