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Prevent
Know the risks, develop a culture of integrityPrevent bribery from happening in the first place by taking steps to recognise the risks and implement effective policies and procedures.
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Detect
Identify and assess issues earlyMonitor for bribery and corruption and assess the effectiveness of controls across your operations. Access guidance to help you design and implement systems to help detect real and possible bribery risks. Implement anti-bribery and corruption systems that continuously adapt and improve.
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Address
Disclose and remediate incidentsProtect your business, comply with laws and enhance processes. Steps to take when bribery or corruption occurs to understand what has occurred and promote a culture of action, self-reporting, remedy and organisational learning.
Case Studies
Designed to help small and medium sized enterprises, these case studies can be easily incorporated into anti-bribery training programs. Find the practical guidance your business needs to work through the challenges associated with preventing, detecting and addressing bribery here.
Implementing an anti-bribery and corruption policy
This is a case study for business owners on how to effectively implement an anti-bribery and corruption policy. Scenario Finlay operates a tech start-up, and is ready to launch an application that may expand into several countries....
Real-life Australian foreign bribery prosecution
Download the case study above This document outlines a real-life case study of an organisation engaging in foreign bribery while operating in a high-risk jurisdiction. Scenario The facts described have been distilled from a recent real-life conviction...
Implementing a whistleblower policy
This is a case study for business owners on implementing a whistleblower policy to help businesses to identify and address staff concerns, including concerns about potential bribery. Scenario Mary manages an events and catering business which...
Conducting thorough due diligence
This is a case study for business owners on the importance of conducting thorough due diligence before and after acquiring another business, to prevent the risk of being implicated in historic or post-merger bribery. Scenario SwiftCo is...
Facilitation payments
This is a case study for business owners on how to identify and respond to a request for a facilitation payment. Scenario Helen produces textiles in a medium-sized business called ClothCo. She recently decided to pursue an...
Investigating an internal complaint
This is a case study for business owners on investigating and responding to an allegation of bribery raised internally. Scenario Sarah’s business, MacNuts Pty Ltd, grows macadamia nuts on rural land in New South Wales. A senior...
Responding to contact by an authority
This is a case study for business owners on how to respond to a bribery complaint raised by an authority. Scenario This is a continuation of the scenario in the Investigating an internal complaint case study. Sarah’s...
Enforcement
This case study demonstrates the types of enforcement actions and penalties that might apply if a company, its officers or employees are found guilty of bribery and corruption offences. Scenario This is a continuation of the...
Common Challenges
These questions offer pathways to resources that help build a foundational understanding of what constitutes bribery and corruption, why acting on bribery and corruption is important for your business and society, and how to anticipate and effectively respond to bribery and corruption risks.
What should I do if my organisation doesn’t have an anti-bribery program?
Knowing how to prevent, detect and address bribery and corruption risks while succeeding in business can be challenging, particularly for small and medium sized enterprises. An anti-bribery program built around the principles of preventing, detecting and addressing bribery and corruption risks can help shield your organisation from the legal and reputational consequences when bribery and corruption occur.
What happens if my business does not take active steps to prevent foreign bribery?
Implementing adequate procedures to prevent foreign bribery and corruption is critical to avoiding potential enforcement action and reputational damage. Australian businesses including those operating overseas are subject to legal and ethical obligations to take active steps to ensure that their compliance frameworks are able to effectively prevent, detect and address bribery and corruption.
I’m working in a country that is prone to bribery and corruption – what red flags does my team need to be aware of?
Australian companies operating internationally can be faced with local customs, expectations, and competitive pressure to bribe – even when this conduct is prohibited under the foreign country’s own laws as well as anti‑corruption laws in Australia and third-party countries. Recognising bribery and corruption red flags can help your organisation to detect and address bribery and corruption risks when operating overseas. Learn how to spot and address warning signs and meet legal requirements to support your business to operate successfully and protect its investment and reputation.
I suspect bribery and corruption in my business and supply chain – what do I do now?
Thoroughly investigating actual or suspected incidents of bribery, including within your own organisation, is critical, and will help you meet your legal obligations, where appropriate, to report to regulators and stakeholders in a timely fashion, to identify and remediate weaknesses in controls and help to demonstrate your company is serious about tackling bribery and corruption. Find what to do and what your obligations are when you identify bribery or corruption concerns.
How does preventing bribery and corruption contribute to sustainable development?
Engaging in the fight against bribery and corruption not only promotes honest competition and makes good business sense. It also helps ensure local communities benefit from your business activity. Corruption can divert funds away from education, health care and other vital public services. It can also exacerbate violence and insecurity and undermine trust in public institutions. Discover why acting on bribery and corruption matters.