Introducing a new anti-corruption approach can be a challenge particularly where you have been the target of an insider threat, or work in an area or country where it is an increased risk. From an operational perspective what should you introduce to identify and mitigate risk.
Education is the movement from darkness to light
How should you introduce a foundation of anti-corruption that can help impact all aspects of your department or organisation approach. Initial questions to consider might be:
Are you able to measure the level of organisation risk from internal and external threats?
Are control measures adequate and do they mitigate identified risks?
Are there enough resources and expertise and in which areas of business operations should they be increased?
Is there a consistent approach to data analysis and do we know which data sources to use?
Is our culture strong enough and how do we develop it if necessary?
Is there strong communication between departments or organisations that are part of the risk identification and mitigation approach?
There are clearly many additional questions that could be asked, however, if you are unable to satisfactorily answer these six questions then consideration should be given to assessing and building the structure of an anti-corruption approach through an education approach.
This may sound simplistic, however, introducing a comprehensive training programme will give leadership, management and operational staff an insight into the expertise and capability requirements or gaps in policies and procedures or systems and controls. Assessing the requirements of a training programme and measuring its benefit and impact should include:
Current typologies of corruption and associated fraud and other financial crime
Best practice risk identification and mitigation approaches
Developing a strategic approach considering organisation risk, prevention, detection, investigation, financial recover, disruption and sanctions where a breach of policy or illicit behaviour is identified
Areas within an organisation that can be targeted and assessing the knowledge level of expertise or quantity of resources, such as, procurement, finance, quality assurance, audit or project management
Education is the most powerful weapon that can be used to change the world
To maximise access to the training, knowledge sharing, and the outputs of any anti-corruption programme consideration should be given to its format that might include eLearning, assignments, virtual and onsite instructor led training.
Information collected and risks documented within this approach will give any organisation a better understanding of its current anti-corruption efforts and give leadership and compliance professionals and greater ability to answer key questions:
What should the internal decision making and change management structure look like
What elements should be considered as part of an anti-corruption strategy
Should additional communication and engagement be introduced with staff, suppliers and partners to build a stronger anti-corruption culture
Is there a comprehensive structure that is able to receive and collect all available risk information and use it to drive operational, managerial and strategic decisions
An education programme isn't a 'nice to have' but should be seen as an integral part of an operational or strategic approach to risk. It is a foundation block on which all other aspects of risk identification and mitigation are introduced and if not done correctly or at all then organisations are just guessing at mitigation and the effects that it will have.
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