A client in the retail sector requested that a review be conducted to establishing the level or bribery and procurement risks faced from an international supplier including whether there was an insider threat and provide recommendations for corrective action where necessary. A company internal assessment of contract files raised a number of concerns that included a current supplier where the due diligence information was missing.
An initial assessment was made of available contract data including available information on the identified supplier. Although a number of individuals had moved to new roles and different jobs, interviews were conducted with relevant staff and management to establish a course of events. It was the client’s intention to conduct a supplier visit and audit so we created a supplier risk questionnaire where their response outlined their anti-fraud procedures and culture. The supplier response established that they had strong anti-fraud procedures that included staff anti-bribery training that they received from a global client. In response to our guidance, during the supplier visit initial onboarding documents were scrutinised and checks were made of materials procured by the supplier and compared to what was provided to the client to determine if there was a product substitution risk.
From the direction given to the client and the information collection during the course of the review, it was established that the bribery and procurement risk to the organisation was low. A review process was recommended and introduced into the organisation that supported the organisations proactive risk mitigation procedures.