Put simply…

Are you consistent?

When your receive a fraud or corruption allegation

or…

data analysis of numerous fraud indicators,

Consistently use the 8C approach

1. Conflicts of interest
2. Company formation
3. Contracts
4. Costs and charges
5. Compliance with procedure
6. Communication
7. Contractor capability
8. Category management

Starting with conflicts of interest

Look for matches when comparing

• staff and supplier executive data
• new vendors and supplier executive data

A client case example

A client had a concern about a bribery risk

from a procurement manager

Simple checks verified that they were

• the director of a supplier
• a shareholder of a second supplier

Simply put…

they were manipulating the procurement process

to give the appearance of competition

but were awarding directly to

their own companies.

And yet…

Introducing procurement procedure

would have prevented it.

So do the basics

• segregate supplier vetting and award roles
• always vet new suppliers for conflicts of interest

Do you do the basics when it comes to fraud risk?

What C would you add to your risk assessment approach?