Thursday, February 23, 2017

Today, MPs have the opportunity to vote on whether to effectively end the use of anonymous companies in the UK’s overseas tax havens. Almost a year ago the Panama Papers demonstrated their importance, with more than half of the companies involved registered in the UK’s Overseas Territories. The proposed measure would give the UK-linked Overseas Territories, such as British Virgin Islands and Bermuda, until 2020 to introduce public registers of the true beneficial owners of companies, as the UK did last year.
Our colleagues at Global Witness has spent many years exposing the dangers posed by the use of anonymous companies registered in the UK’s Overseas Territories by corrupt or criminal individuals, and has campaigned for transparency to bring this abuse to an end. In almost all of the major corruption cases we’ve investigated, anonymous companies have been at their heart.
So, on the eve of tomorrow’s vote, we’ve produced a run-down of our top 10 corruption cases run through anonymous companies in the Overseas Territories:
  1. Teodorin Obiang, the son of the President of Equatorial Guinea, took and spent $38 million of his country’s money on a private jet using an anonymous company based in the British Virgin Islands, according to the case against him made by the U.S. Department of Justice.
  2. Kenya lost out on at least $4.7 million due to overpriced government contracts awarded to Anglo-Leasing, a British Virgin Islands anonymous company that authorities believe could be connected to officials close to the contracting process The loss was part of a larger $1 billion contracting scandals involving several anonymous companies.
  3. As part of an estimated £6 billion arms-dealing corruption scandal, BAE made payments of over £143 million through a British Virgin Islands anonymous company, even though it should have been aware that much of this money was likely to be used as bribes to win contracts.
  4. The husband of the then Prime Minister of Pakistan allegedly received $10 million in corrupt payments in relation to gold import licenses through a British Virgin Islands anonymous company.
  5. Alcoa, the world’s third largest producer of aluminium, used anonymous companies formed in the British Virgin Islands to transfer millions of dollars in bribe payments to Bahraini officials to secure a supply deal.
  6. A subsidiary of Halliburton paid $132 million to an anonymous Gibraltar-based company to be used, in part, for bribes for high ranking Nigerian officials in exchange for a lucrative contract to build a liquefied natural gas plant.
  7. The wife of a former Taiwanese President used an anonymous British Virgin Islands company to buy a $1.6 million Manhattan apartment using the proceeds of a $6 million bribe she received for influencing her husband to approve a contested company merger.
  8. An anonymous British Virgin Islands company was used to buy property in Brussels as part of a scheme by the former President of Zambia to steal $25 million from the Zambian Ministry of Finance.
  9. An anonymous British Virgin Islands company secretly controlled by a major mining company signed corrupt deals with the wife of the President of Guinea, as part of a deal to access iron ore mining rights worth billions of dollars.
  10. The Nigerian dictator Sani Abacha used British Virgin Islands companies to hold at least $450 million of the $2 billion he stole from the government during his time in power.
As all of these cases show, there is overwhelming evidence that anonymous companies in the Overseas Territories help fuel a staggering amount of corruption around the world, and this list is by no means comprehensive. In all of these cases, the secrecy provided by the anonymous companies was vital to the operation of these schemes.
Making the identities of the true, beneficial owners of companies public also helps businesses know who they’re doing business with, helps detect crime, saves money and helps prevent insecurity.
Tomorrow, all MPs should shine a long overdue light on these shady companies and vote to end anonymous companies in the UK’s overseas tax havens.

Thursday, February 16, 2017

Fifteen bright young minds from Malawi, Namibia, South Africa, Zambia and Zimbabwe came together late last year to brainstorm innovative solutions to combat land corruption.
Across Africa, one in every two people needing access to land-related services is affected by corruption. This could be a politician issuing title deeds to a select community to cement power ahead of local elections, a business deal between land developers and governments that displace local farmers, or traditional authorities abusing their power to sanction land grabs.
For young people, land-related corruption in rural areas can sap entrepreneurial spirit and restrict access to employment, encouraging migration to overcrowded urban centers where competition for jobs is even greater.
At the three-day workshop our young change makers were mentored by leading social entrepreneurs in order to develop solutions to boost integrity in the land sector. Participants from different countries were encouraged to work together to ensure a wider reach for each solution.
The four best projects to come out of this initiative have been awarded seed grants so they can be developed further.

Here’s a glimpse of what they are about:

From Namibia: Hilda Liswani, aged 24 and Ray Mwareya aged 33

Ray and Hilda want to find a way to stop “foreign companies coming into rural areas in Zimbabwe and Namibia, and grabbing land for development without consulting local communities.”
Their solution is to work with an existing community-based digital media organisation in Namibia thatHilda currently runs and develop an online platform that uses open data and reports from whistleblowers to expose land invasions.
The idea is to equip community members with low-cost mobile camera phones with GPS technology to take photos of land grabs in their areas and send them to the platform. Ray and Hilda will use this information to draw up heat maps of suspicious activity and publish them online.
As an experienced investigative reporter, Ray is planning to train community members on how to use the phones in a way that doesn’t compromise their safety. The team eventually hopes to share information they gather with authorities and push for action to be taken against the perpetrators.

“Despite being the custodians of their own land for thousands of years, the communities of the rural Eastern Cape have very little power over its ownership … they need better tools to protect their most valuable asset.”Ariel Lashansky, young social entrepreneur.

Eastern Cape, South Africa: Ariel Lashansky, aged 28

“Despite being the custodians of their own land for thousands of years, the communities of the rural Eastern Cape have very little power over its ownership. Earlier this year, I founded an NGO and tried to set up a football field for the community,” said Ariel.
“A government department intervened and claimed ownership of the land allocated for the field. I later found out that officials had sold this land to a local businessman so he could develop it for his own commercial interests. This is not an isolated incident and these vulnerable communities need better tools to protect their most valuable asset. The problem is the lack of a proper land registry and transparency around local land ownership.”
Ariel’s idea is to work with a Ghanaian tech start up with experience in building decentralized tamper-proof ledgers to record land title deeds. As part of the partnership, the Ghanaian team will travel to rural Eastern Cape in 2017 with specialized equipment, including drones, to help the local community survey their land.
This will be the first step in Ariel’s mission to collect property ownership details and land usage rights in a secure, easily-accessible electronic format. He’s hoping this could then be used as a model to be used in other areas in South Africa as well.


From Cape Town and Mpumalanga, South Africa: Nokubonga Ndima (aged 25) and Omari Christophe Koza (aged 30)

Nokubonga and Christophe’s project will tackle the effects of corruption in South Africa’s land reform process, particularly cases of village tribal authorities unlawfully trading farmland that has been returned to local communities affected by apartheid-era land dispossession. “We’ve also noticed that land returned to villagers often does not come with a title deed, therefore it still officially belongs to the state,” says Christophe.
“This has intensified poverty and unemployment in rural areas and bred feelings of poor self-worth among local farming communities,” he adds. Their solution is to work with land redistribution beneficiaries and tribal authorities in Makokeni village in rural Mpumalanga province – where Christophe is currently based – to provide training on organic farming techniques and leadership mentoring for village youth. The team hopes this will promote a culture of responsibility and accountability for the land the community is cultivating, alleviate joblessness and empower the community to hold their leaders to account.
“We will also work with the department of rural development and land reform to ensure beneficiaries receive the title deeds to their land,” says Christophe.



From Zimbabwe and Malawi: Tswarelo Mothobe (aged 34) and Ceaser Chembezi (aged 26)

This team believes land corruption thrives when communities are left in the dark about their rights.
Living in Bulawayo, Zimbabwe, and Blantyre, Malawi, respectively Tswarelo and Ceaser have experienced this first-hand. “In both our cities, there’s a lack of public information about how to acquire land, what one’s land rights are, how to spot corruption and where to report it. When information is shared, it’s often clouded in jargon or disseminated during high-level government meetings which the public can’t access.”
The two hope to turn this around by using their seed grant to design attention-grabbing banners with vital land-related information and contact details that will be put up in public spaces like market places, taxi ranks and bus terminals.
They’re also looking at putting large stickers on the sides of taxis and buses, designing food takeaway packaging with anti-corruption messaging and hosting public poetry and drama sessions to spread the word.
“We’ve got good design skills within our team and are going to speak to taxi associations, packaging companies, local government authorities and arts and culture collectives to partner with us,” Tswarelo says.
“Our primary target is young people between the ages of 16 and 35 who are routinely excluded from critical conversations with our governments. Ultimately, we’re hoping our project will inspire a culture of participation so that young people will demand fair inclusion in decision-making processes.”

Source: Annette Jaitner, Transparency Blog

Sunday, February 12, 2017

Zimbabwe’s crippling cash shortage has left a black hole in the financial system that’s crushing the rest of the economy.
“We deposit the cash and it becomes theoretical, ephemeral,” Mohamed Salam, who owns several small stores selling building supplies in Harare, the capital, said in an interview. “My bank balance says it’s there, but it isn’t. I can make payments electronically to local suppliers, but I can’t pay foreign suppliers.”

The liquidity squeeze has left companies unable to pay their workers in cash and foreign suppliers, driving many out of business, and added to the ranks of more than 3 million people who’ve become economic exiles. The economy probably shrank 0.3 percent last year and is set to contract 2.5 percent this year, according to the International Monetary Fund.
Zimbabwe abandoned its own currency eight years ago and adopted mainly the dollar, initially halting hyperinflation. Now, with a floundering economy and a strong dollar stoking imports and curtailing exports, banknotes have virtually disappeared, prompting the central bank to order private lenders to cap customer cash withdrawals at $150 a week. While the Reserve Bank estimates about $4 billion is circulating in the economy, Confederation of Zimbabwe Industries President Busisa Moyo says the amount may be as little as $100 million, about a quarter of what he believes is needed.
“The economy is in what could turn into a death spiral,” Steve Hanke, a professor of applied economics at Johns Hopkins University in Baltimore who studied the advent of hyperinflation in Zimbabwe, said in an e-mailed response to questions. He blamed the government of President Robert Mugabe, 92, for being “so incompetent and corrupt and prone to making bad economic policies.”

Payments Halted

A dearth of foreign exchange forced brewer Delta Corp. Ltd., almost 23 percent owned by Anheuser-Busch InBev NV, and telecommunications company Econet Wireless Zimbabwe Ltd., the nation’s two biggest businesses, to suspend dividends and halt payments to foreign suppliers late last year. Both companies said they don’t foresee any operational disruptions. Econet shareholders agreed to a company plan to raise $130 million in foreign currency.
A number of retailers and other businesses are offering big discounts to cash-paying customers and limit the amounts they can charge on credit cards or refuse to accept them altogether.
“The country has run out of money and we have completely lost the ability to pay for imports,” said John Robertson, an independent economist in Harare. “This comes against a backdrop of falling productivity as companies fail to access vital inputs because there’s no foreign currency to pay for them. As long as government continues to do things that discourage both local and foreign investment into the productive sector, the situation can only get worse.” 

Majority Ownership

The economy has halved in size since 2000, when militants backed by Mugabe seized white-owned farms, crippling agricultural output and exports. The government also deterred investment by enacting laws aimed at forcing some companies operating in the country to have majority black ownership and issuing conflicting messages on how they will be implemented.
Officials at CBZ Holdings Ltd. and the Zimbabwean units of London-based Barclays Plc and Standard Chartered Plc, the nation’s three largest lenders, said no one was available to respond to questions on the cash crisis.

In a bid to ease the banknote shortage and discourage cash hoarding, the government began distributing so-called bond notes in November, with about $88 million of the dollar-linked securities issued so far out of a planned $200 million that are backed by a loan from the African Export-Import Bank. While banks and most large retailers accept the proxy currency, many small stores, informal traders and taxi drivers won’t, or price them at as little as 70 percent of their dollar face value.

Economic Distortions

Hanke, who’s also director of the Troubled Currencies Project at the Washington, D.C.-based Cato Institute, said the decision to issue the bond notes was a disaster.
“Zimbabwe is no longer a pure dollarized system, but a mixed system, one that is bound to fail,” he said. “More bond notes will only add fuel to the demand for hoarding of what is viewed as being the superior currency and store of value in Zimbabwe, the U.S. dollar. As the issuance of bond notes increases in response to the hoarding frenzy, the premium on dollar notes to bond notes will widen and so will the distortions in the economy.”

Source:  Brian Latham and Michael Cohen, Bloomberg

Tuesday, February 7, 2017

When former Ukrainian President Viktor Yanukovych fled the country at the end of the Maidan revolution protestors in 2014, activists and citizens visited his now abandoned Mezhyhirya mansion. What they witnessed was the shear amount of wealth that Yanukovych had seemingly acquired through corruption. Classic cars, a personal zoo and a full-size replica Spanish Galleon were all very visceral examples of how a corrupt elite have stolen so much from the Ukrainian people.
It’s been three years, a change of government and billions of euros of international aid since the flames of Maidan. Yet in 2015 only $3,813 of stolen assets were recovered. And in 2016 only $5,683 has been recovered. Repeatedly, major donors like the IMF, the US and the EU have come forwards to express serious concerns about Ukraine’s progress in fighting corruption and threatened to pull their funding from the heavily indebted country.
The Ukrainian authorities have made some important steps in preventing corruption, such as the creation of the National Anti-Corruption Bureau (NABU), mandatory public asset declarations for public officials and the roll-out of the ProZorro e-procurement system. However, there has been little in the way of success stories when it comes to recovering stolen assets at home and abroad.

The most well established measure for retrieving stolen assets from abroad is mutual legal assistance, which is legal tool where by a court or law enforcement agency in one country can ask a court in another to freeze the assets of an individual or company pending trial and then be repatriated to the claimant. This tool has been traditionally quite successful in returning stolen assets in cases of corruption.
However, legal systems are different in different countries and therefore in order for mutual legal assistance to operate effectively there needs to be a degree of harmonization between the processes in both jurisdictions and time for things like translation. At present a court order to seize assets in Ukraine is only valid for one month. Given the time it takes to translate documents and process claims across borders this is clearly a massive hindrance to Ukraine retrieving stolen assets in places like Europe. 
Short court orders is just one example of how Ukraine’s judicial system is in dire need of reform. An underfunded, untrusted and overwhelmed judiciary stands in the way of asset recovery. According to one investigative judge at the Third Annual Recovery of Proceeds of Grand Political Corruption in Ukraine conference on December 15 & 16 2016, around 200 Ukrainian courts have just one judge, whom then must judge criminal, civil and commercial cases.
A new and specialised anti-corruption court could provide the answer. A court focused on corruption and criminal procedures would be able to review cases quickly and if composed of newly trained staff it could improve trust in the legal process, in a country where 61% of people think judges and courts are corrupt.

The full-size replica Spanish Galleon at Yanukovych’s former residence Shortly after Yanukovych fled into exile, supposedly into the quiet and cozy Moscow suburbs, the EU used the unusual tool of sanctions and asset freezes against dozens of ex-Ukrainian officials on the grounds of the misappropriation of state funds. This highly political move was designed to give the new government breathing room and preserve some of the $7.5 billion dollars that Yanukovych and his cronies are alleged to have stolen.
While this sent a message from Brussels that the EU was willing to help, sanctions against individuals for misappropriation are difficult to hold up in court, and the European Court of Justice has already ruled against several cases. The sanctions department of the External Action Service (EEAS) has to rely on documents provided by the Ukrainian authorities to prove misappropriation, which cannot be verified without the aid of the very same authorities. These documents have since proven easy targets for slick lawyers operating on behalf of those on the sanctions list.
Secondly, sanctions are a tool which requires the political agreement of 28 EU foreign ministers and have only been used in special circumstances. To use sanctions on a regular basis would require a major overhaul of how EU foreign policy operates and an increase in resources and mandate for the EEAS. In today’s political climate, however nice a thought for anti-corruption campaigners, it seems unlikely that we’ll see the EU throwing sanctions on every third country national who’s been stealing from their own state.
However, what the EU can do is ensure it keeps up the existing sanctions, subject to legal proceedings of course, against Ukrainian ex-officials, buying Ukraine time to improve the efficiency of the judiciary, create an anti-corruption court and build strong legal cases against those who are thought to have stolen public funds. Then Ukraine can use the more tried and tested method of mutual legal assistance requests. The EU and other international actors should also continue to provide technical assistance throughout this reform process.
Asset recovery would not just show Ukraine’s commitment to overcoming corruption, it would also provide the national budget with a much needed source of revenue to help rebuild the country. And perhaps most importantly it will send a message to those still stealing from the state that it’s time for justice.

Source: Alex Johnson, Transparency International Blog

Wednesday, February 1, 2017

Currently estimated to cost five per cent of the world’s total GDP, or US$2.6 trillion per annum, corruption is now the third largest industry globally and is growing. In response, anti-corruption legislation around the world is being strengthened, with a growing emphasis now placed on enforcement and compliance. Organizations not only need to have an anti-corruption program in place, but are increasingly required to prove its effectiveness.

Eight mistakes that boards & management need to be aware of when establishing anti-corruption program

Unfortunately, a growing number of anti-corruption program are failing to meet this new challenge; the most recent being the French industrial group Alstom. Despite having an integrity and anti-corruption program in place, Alstom was recently fined US$277.3 million to resolve criminal charges relating to a widespread corruption scheme. The scheme involved the payment of at least US$75 million in secret bribes to government officials around the world.
So what went wrong? Why was it that its anti-corruption programme failed and failed so miserably? While there is no silver bullet to guarantee success, there are a number of common pitfalls, which, if avoided, can dramatically decrease the chance of failure.
While not exhaustive, outlined below are the most common mistakes that boards and management need to be aware of when establishing anti-corruption program.

(1) Lack of political will and commitment at the top


The strongest influence on the direction of an organization’s ethical compass is its leadership, making the ‘tone set at the top’ the most important influence in shaping the success – or failure – of its anti-corruption program. This requires genuine commitment. It is not simply a matter of making anti-corruption an organizational priority, but having sufficient political will to prioritize principle over economic pressures. Too often, a blind eye is turned when questionable behavior is needed to ‘win’ business or meet revenue targets.
Without genuine commitment at the top, even the best anti-corruption program will end up as window dressing. Put simply, if its leaders are not authentic about countering it, why should its managers and staff be? A prime example is FIFA, which had an extensive ethics and anti-corruption programme in place (see Box 1, below). Despite this, it is embroiled in multiple corruption probes that has led to the suspension of its long-standing president and seen 23 of its senior officials charged (along with two other officials and five corporate executives) with racketeering, wire fraud and money-laundering spanning a 24-year period.

FIFA Integrity and Anti-Corruption Framework
Tip: A simple litmus test to gauge leadership’s commitment to an anti-corruption program is to ask how many senior managers have attended the standard anti-corruption training workshop traditionally advocated for staff?

(2) Inadequate resources being made available


While making necessary resources available is a sine qua non of any anti-corruption effort, it is often overlooked. According to PwC’s 3rd Annual State of Compliance Survey, while 80 per cent of respondents had a global turnover in excess of $1billion, 41 per cent had a compliance budget of just $500,000 (or 0.05 per cent of their turnover) or less.
If we overlay this with the Association of Certified Fraud Examiners (ACFE) statistic that the typical organization loses five per cent of revenues each year to fraud, the $500,000 compliance budget above is expected to tackle nominal annual fraud seepage of $50 million or more. In other words, for every $100 in fraud incurred, the organization makes $1 available to counter it: a ratio of 100:1. When factoring in non-fraud-related forms of corruption, this ratio widens even further, making the $500,000 budget appear somewhat symbolic.
Tip: While resources are a key enabler for a successful anti-corruption programme, throwing money at a problem is no guarantee of solving it. Just as important is ensuring that the resources made available are of the right mix

(3) Using a generic ‘one size fits all’ approach


While corruption is a generic problem, it has no generic solution. Differences in cultural beliefs, value systems and norms mean that what is acceptable in one country or society (in particular when defining corruption) is inappropriate in another.
Anti-corruption and compliance efforts traditionally use a ‘factor approach’, which relies on the use of a checklist of actions or components that need to be included within various anti-corruption initiatives. Overly generic in nature, this ‘one-size-fits-all’ approach ignores the contextual differences highlighted above.
The issue here is flexibility. An anti-corruption program needs to take general factors into account, while at the same time, being sensitive to differences in local circumstances. How corruption in Sub-Sahara Africa (which is generally opportunistic in nature) is tackled, is different to how corruption in parts of Asia or Eastern Europe (which is far more systemic) is countered. If an anti-corruption program does not take these differences into account, success will at best be limited.
Tip: While the basic foundation for an anti-corruption framework should be built around a common set of principles, the individual components (and stepping stones) that go into each of its pillars need to be tailored to meet the particular corruption context faced.

(4) Absence of ownership in the middle


While the ‘tone set at the top’ is critical to establishing the foundations of a successful anti-corruption program, ownership ‘in the middle’ is vital for embedding it. While leaders set the direction, middle management is where the rubber meets the road. This group – more then any other – have direct influence on an employee’s day-to-day behavior, creating a multiplier effect that places them at the front-line of entrenching corruption prevention. If middle managers feel they don’t own the initiative, the risk of failure is high.
This is supported by the results of a series of internal KPMG staff focus groups, which found that a staff member’s immediate supervisor was the first person they would turn to in the event of a potential problem or ethical question. In this context, it was the firm’s third- and fourth-year associates who were identified as being the critical link in setting the tone and driving leadership’s ethics and anti-corruption-related compliance messages throughout the organization.6
Tip: Given their direct influence over day-to-day staff behavior and the multiplier effect they can have, middle managers need to be the focus of additional anti-corruption training/sensitization.

(5) Failure to strongly enforce wrongdoing


When a long-standing chairman of a leading anti-corruption agency was asked what (in his opinion) was the most effective deterrent to corruption, he responded: “Executing somebody!” While extreme, the underlying message is clear: the penalty for being caught needs to far outweigh any potential benefits that can be gained from wrongdoing. Failure to strongly and consistently enforce punitive sanctions will directly undermine the credibility of an organizations anti-corruption program.
The importance of this is highlighted in the case of a large multi-national with extensive operations in Southern Africa. When a forensic audit found its local CEO had acted corruptly, rather then risk an expensive court case that would generate negative publicity, they instead offered him a golden handshake. The message sent to staff (who had all been closely following the case) was clear: it paid to be corrupt. Not only do you get to keep what you took, but you are then paid to leave! While this decision may have seemed logical at the time, the direct result was a marked increase in corruption cases throughout the region.
Tip: Strong, consistent enforcement of anti-corruption sanctions need to be viewed by the organisation as an opportunity (not as a threat), as it remains one of the single most effective anti-corruption deterrents available.

(6) Over-reliance on hard controls


Many anti-corruption program focus on the use of ‘hard controls’, such as structures, policies and procedures, forms and rules etc. Based on a system of ‘checks and balances’, these controls work by simply being in place. This makes them relatively easy to test and audit, hence their popularity when ‘results’ need to be shown.
The downside, however, is that the increasing complexities of today’s business environment means that as each additional risk is identified, there is a tendency for organizations to react by overlaying one set of hard controls over another. This layering effect can rapidly result in an environment where managers (and staff) bypass the system simply to ‘get things done’. Once this becomes the modus operandi, the control system as a whole becomes redundant.
Tip: An anti-corruption program should be made up of a mix of hard and soft controls (see the Table below). Performed by people, soft controls (such as an ethical culture, competence, a commitment to quality and fairness) are active in nature, and harder to audit. They are, however, extremely effective when it comes to corruption prevention.
Table 1: Hard vs. Soft Controls

Table of Internal Controls - Hard vs Soft Controls


(7) Ignoring the ‘design-reality gap’


While many anti-corruption programs tend to fail during the implementation phase, in many cases the underlying cause can be traced back to a mismatch between the expectations built into the program’s design and the actual realities on the ground. The larger the gap, the greater the risk of failure.
A successful anti-corruption program requires a clear understanding of both the ‘who’ and the ‘how’ in the design process. The problem here tends to be twofold: first those tasked with design have a lack of understanding or exposure to the realities on the ground; and secondly the ‘design’ objectives aren’t aligned with the ‘real’ objectives and values of delivery stakeholders. The result? An over-assessment of what the program can effectively achieve.
Tip: Ensure that implementation stakeholders are included in the programme’s design phase. This, and breaking each initiative down into ‘bite-sized’ chunks, will help minimise the residual design-real it y gap within each component, making successful implementation more likely.

(8) Inadequate training and sensitisation


Training is an area that is consistently identified in anti-corruption enforcement actions as being inadequate. Too often organizations assume that circulating a policy on anti-corruption is sufficient in itself and fail to provide the training and sensitization necessary to anchor it.
As behavioral change is at the heart of corruption prevention, training is a v ital. ingredient to a successful anti-corruption program. Staff and managers alike need to understand how the organization defines corruption and what types of conduct may constitute corrupt or unethical behavior. If they are unable to recognize the warning signs and red flags that indicate the presence of corruption, or are not equipped with a framework on how they should act – and react – when faced with corrupt activity, an organizations anti-corruption program will fail to tap into its key anti-corruption resource: its own staff.
Tip: An anti-corruption program should include training, training, and more training! Sensitization and training workshops need to be tailored to specific corruption risks and responsibilities and should clearly communicate that compliance is the responsibility of all staff.

But is getting it right as easy as it sounds ….?


While not exhaustive, the above tips will dramatically increase the chances of a successful anti-corruption programme. There is, however, no quick fix. Even among organizations where anti-corruption compliance is well-established, sustained, on-going commitment and energy is essential. Anti-corruption efforts in general should not be viewed as static, but iterative in nature. To be effective, a programme must be able to anticipate and adapt to new risks as the organization and its environment changes. Regardless of this, one thing is clear – given the increasing penalties now being levied for breach of anti-corruption legislation around the world (in particular in the US and UK), boards can no longer afford to ignore the topic – or the associated risk it poses to their organization.

Source: Jeremy Sandbrook, integritas360 

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