totalling more than £1 billion. Businesses of all sizes have had much to deal with over the past 18 months with many trying to survive financial hardships caused by the COVID pandemic. It is, therefore, inevitable that compliance issues will have been put on the back burner by many during this time. However, as businesses begin to recover, it will be important to ensure that they do not seek to scale back, or even ignore, the risk of bribery. For many organisations this may be an opportune time to take stock of what procedures they have in place, and to refresh and improve them. After all, compliance is an ongoing obligation and should always be evolving for the better.
As we know from recent experience, a lot
can happen in a year, let alone ten years. T ere are businesses that invested a lot of time, energy and cost into the development of anti-bribery procedures when the Act came into force but their policies have not seen the light of day since. A number will have seen substantial operational change in the last year alone, some of which will impact on their internal and external bribery risk. It is important that businesses update their procedures to take into account the impact of recent events and changes. Considerations may, among others, include: - Have there have been recent changes of personnel in senior teams and positions of trust? Are they familiar with organisational policies and
procedures and have they received appropriate levels of training? - Do any anti-bribery and corruption policies need reviewing and updating? Are they still appropriate and suffi cient to satisfy the needs of the business? - Has the risk of exposure to bribery changed and should risk assessments be reviewed? Many supply chains have been disrupted due to the dual impact of the pandemic and Brexit. Businesses have had to adapt by sourcing products and raw materials from elsewhere, including from countries with higher levels of corruption. Trade may be expanding into new markets and some of these may pose a higher risk of bribery which will need to be assessed and managed. - Will new ways of working, such as increased home working, mean that there is less supervisory control and oversight of certain teams and personnel? How will this be monitored and managed?
It is understandable that now might not seem like the best time to be focusing any energy into compliance when the focus is on recovery. However, during turbulent economic times, instances of fraud and corruption increase significantly. Businesses and individuals in diffi culty will be more inclined to resort to extreme action with the old adage of ‘desperate times call for desperate measures’ being the driving force behind many ill-advised decisions. There have been many cases of hardship brought on by the
pandemic and it is not surprising that some people will feel the need to take unacceptable risks. It is, therefore, essential to ensure that, during the return to more normal working arrangements, any anti-bribery procedures are reviewed, refreshed and properly embedded within your organisation.
For more information, contact Robert Starr on 01604 222122 or at
robert.starr@
howespercival.com
ALL THINGS BUSINESS
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