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Measuring Anti-Corruption Culture: A Comprehensive Framework for Assessment

Updated: Aug 29, 2023

The true essence of measuring anti-corruption culture lies in assessing how deeply values are embedded, and how consistently they guide decisions

anti-corruption culture

If we are to preserve culture we must continue to create it


Corruption and the insider threat remains a persistent challenge in international business, undermining governance, economic development, and social equity. Governments, organisations, and civil societies are actively working towards fostering anti-corruption cultures to combat this issue. However, measuring the effectiveness of anti-corruption efforts has proven to be complex due to the intangible nature of cultural changes. In this article, we propose a comprehensive framework for measuring anti-corruption culture, providing a structured approach to assess the impact of various initiatives.


Are you able to measure the performance of your organisation's anti-corruption culture and is the coordination of your communication strategy and engagement with staff, partners and suppliers adequate enough to make an impact in reducing your bribery and corruption risk?


To examine and understand an organisation's anti-corruption culture or whether it meets your perception of its impact and how it protects organisation revenues, you must consistently measure performance against your organisation anti-corruption approach and communication.


THE NEED FOR MEASURING ANTI-CORRUPTION CULTURE

Anti-corruption culture refers to a set of shared values, beliefs, attitudes, and behaviours that promote transparency, integrity, and accountability while discouraging corrupt practices. While several anti-corruption strategies and policies may have been implemented, there may be a lack of standardised methods to evaluate the cultural shifts that result from these efforts. Measuring anti-corruption culture is essential for several reasons:

  1. Evidence based decision making: Organisations need reliable data to make informed decisions about the effectiveness of their anti-corruption initiatives.

  2. Resource allocation: Limited resources should be allocated to initiatives that yield the greatest positive impact on anti-corruption culture.

  3. Benchmarking: Comparative data helps organizations assess their progress over time and against peers.

  4. Accountability: Transparent measurement mechanisms enhance accountability and encourage stakeholders to remain committed to anti-corruption efforts.


ETHICAL RESPONSE Vs ANTI-CORRUPTION CULTURE

Where an organisation's ethical response doesn't match what it aspires to achieve in creating an anti-corruption environment then it is unlikely that it will be able to build a sustainable culture.


Where there is evidence of improper conduct or poor performance in dealing with ethical issues, then an unethical culture or behaviour is likely to be tolerated. This type of behaviour will limit the engagement and interest of staff or suppliers in reporting suspicions of fraud that will ultimately leave an organisation with a limited understanding of what its risk picture is. Examples of such behaviour might include:

  • Ethical issues that are reported through line management that aren't addressed

  • Whistleblower reports that aren't appropriately dealt with or an individual is targeted by the organisation through bullying or intimidation.

  • Improper treatment of suppliers or abuse of procurement route

  • using conflicts of interest or corrupt activities in obtaining or retaining contracts

Measuring anti-corruption culture is akin to assessing the heartbeat of an organisation's integrity – it reveals the health of its ethical core

DESIGN OUT FRAUD

Where an organisation communicates a strong message that an organisation takes corruption seriously, highlighting the types of corruption and associated fraud or financial crime that it is being targeted by and where there is a proactive response and a greater chance that individuals will be caught, then it is likely that fraud and financial loss will reduce. Key areas of communication an anti-fraud message might include:

  • During the onboarding process, confirming conflicts of interest, ability to perform contracts and assessing a vendors own anti-fraud culture

  • Training and awareness provided to staff and suppliers that outline key typologies of fraud and where to report it

  • Ensuring that there are clauses within the contract that include anti-fraud and anti-bribery clauses, competition clauses to mitigate bid rigging, audit clauses, sub-contractor approval clauses

  • Financial, procurement and quality controls including 5 way matches before invoices are approved

  • Ability of an organisation to receive and respond to reports of suspicions of fraud or irregularity from staff, suppliers or consultants

  • Strong recruitment procedures to ensure that individuals with conflicts of interest or fraud risk are identified


CREATING AN ANTI-CORRUPTION CULTURE


Enhancing the culture of an organisation requires the coordinated construction of a communication strategy that builds on various aspects of an organisations intention to engage all staff, partners and suppliers in its drive to identify and mitigate risk.


When planning and developing a communication strategy to build organisational culture, consideration should be given to internal and external messaging including the message that is being sent out by our actions and activities that we introduce. A number of areas should be considered:


  • Leadership, ownership and responsibility for the organisation's anti-corruption culture and strategy that includes demonstrating the tone from the top, setting an example for ethical conduct

  • Communication with staff and suppliers including a reporting process for risk, having a whistleblower protection policy and education and awareness that outlines an organisations risk and their approach to mitigation

  • Internal engagement with staff that might include anti-corruption forums, having an anti-corruption platform and central library that hosts organisation policies, messages and other communication

  • Supplier engagement including briefing, reporting process and visits to support their engagement with your organisation's anti-corruption approach

  • External engagement and communication including involvement with local, national or international forums to support and enhance an organisation anti-fraud focus

  • Anonymised feedback process that supports early risk identification and measurement of culture

  • Success measurement and performance indicators are an important part of monitoring and reporting positive outputs of the anti-corruption culture including areas that can assist its development

INTRODUCING A COMPREHENSIVE FRAMEWORK

The proposed framework comprises of five key dimensions, each consisting of multiple indicators:

  1. Leadership and governance: Tone at the top and being an example to leadership, management and staff. Assessing the commitment of leadership to anti-corruption values through public statements and behaviour.

  2. Governance: Introducing governance structures and the evaluation of compliance with systems and controls, policies and procedures that ensure transparency and accountability.

  3. Ethics environment: Whistleblower protection measures and organisation's policies and practices for protecting individuals who report corruption. Gauging the norms and values among employees compared to published values through surveys and interviews.

  4. Transparency and communication: Introducing a communications approach surrounding anti-corruption culture and action taken by an organisation. Making documented decision making availability to all staff, creating an environment of openness and introducing effective channels for employees to raise concerns.

  5. Accountability: Implementing measures that are consistent and fair in disciplinary actions taken against individuals involved in corrupt practices. Introducing a system of recognition for individuals who display integrity and report corruption are recognised.


ASSESSMENT METHOLOLOGY

The framework outlines a mixed-methods approach for assessment. It combines quantitative data from surveys and existing organisational records with qualitative insights gathered from focus groups, interviews, and case studies. This approach provides a comprehensive understanding of the organisation's anti-corruption culture, capturing both quantitative trends and qualitative nuances.


CONCLUSION

Communication and engagement with staff, suppliers, partners and third parties is integral in building an organisations anti-corruption culture. Publishing policies isn't enough and anti-corruption efforts should focus, not only on interaction with individuals but also look at how staff can be involved and drive an organisation's approach. After all, it is an organisations staff that understand where the challenges and weaknesses are within an organisations systems and controls.


As organisations strive to eradicate corruption, understanding the impact of anti-corruption initiatives on cultural change becomes paramount. The proposed comprehensive framework offers a structured way to measure anti-corruption culture, enabling organisations to assess their progress, identify gaps, and make informed decisions. By embracing evidence-based evaluation, stakeholders can collectively work towards fostering integrity, transparency, and accountability in their respective domains.


So where do you start, is the challenge too big or do you need external guidance. Is doing nothing an option?



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