SUPPLY CHAIN RESILIENCE


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and continue to prioritize anti-bribery compliance measures. The sudden need for greater flexibility, expedited new business relationships and quickly shifting supply chains may present additional risks, but adequate compliance measures undertaken now can prevent legal, financial and reputational damage later.


E-government services


Because the number of interactions with government officials positively correlates with the risk of encountering bribe demands, companies should take advantage of e-government services wherever possible. Using publicly available platforms such as the TRACE e-Gov Portal, a comprehensive database of links to country-level e-government services and resources in more than 100 jurisdictions, can reduce employees’ and third parties’ exposure to arbitrary demands by public officials.


Training and company culture


On-the-ground decisions in response to bribe demands must be made quickly, and often in different time zones, making training and awareness of company policies critical for all employees and third parties in the field. Scenario-based training is ideal. An employee who has had the chance to work through a specific situation in training is more likely to respond appropriately. Online multilingual anti-bribery training makes it easy to get new employees and third parties up to speed quickly. While annual training should be standard, regular refresher courses can help to keep anti-bribery policies and best practices top-of-mind between training cycles.


A consistent culture of compliance can also help to mitigate the risk of violations, and maintaining a steady message of zero tolerance is especially important during times of crisis. The anti-bribery policy and code of conduct should be well understood throughout the organization and among third parties. Senior management should continue


to emphasize the importance of compliance through frequent communication and unwavering commitment.


Approval and recording processes


Anti-corruption laws often expressly require companies to keep accurate books and records, and there should be adequate approval and record-keeping procedures in place throughout the supply chain. Consider which areas might carry heightened risk and require more monitoring, how financial flows can be better accounted for, and where additional checks and balances might be beneficial.


Reporting and helpline procedures


Adequate channels for asking questions and reporting concerns, bribe demands and compliance violations are critical to sound operations. All employees and third parties throughout the supply chain should be aware of reporting mechanisms, including helplines, hotlines and other channels of communication, and there should be express protections for whistleblowers.


COMPLIANCE IN TIMES OF CRISIS


As the transport industry adjusts to the pressures of the COVID-19 pandemic, companies are wise to maintain vigilance


About TRACE


TRACE is a globally recognized anti-bribery business association and leading provider of shared-cost third party risk management solutions. Members and clients include over 500 multinational companies headquartered worldwide. TRACE is headquartered in the United States and registered in Canada, with a presence on five continents. For more information, visit www.TRACEinternational.org


There is little reason to believe that anti- corruption enforcement authorities will be more lenient in light of the crisis. Some business operations are likely to be more closely scrutinized, given that many ongoing operations are benefiting directly or indirectly from a significant increase in government spending. Banking on enforcement authorities being too distracted to prosecute foreign bribery cases may prove to be a reckless business plan. Conducting high-level risk assessments before entering new markets or opening new routes, thoroughly vetting new business partners, promoting compliance throughout the organization, and installing additional precautions where necessary protects companies, individuals and communities.


Corruption contributes to lost cargo, lost revenue and lost trust. Given the increased and urgent demand for certain products like medical supplies, along with disrupted supply chains and the potential for closer scrutiny, adequate anti-bribery compliance measures are a critical part of any effective COVID-19 crisis response playbook.


‘On-the-ground decisions in response to bribe demands must be made quickly, and often in different time zones, making training and awareness of company policies critical for all employees and third parties in the field.’


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