Cultural risk factors for an effective compliance program

Posted on September 19, 2022

Cultural risk factors that must be considered to effectively implement an Anti-Bribery and Corruption (ABC) compliance program include:

  1. Culture of integrity, ethics, and compliance: The organisation must establish and communicate messages clearly and consistently to foster a culture of ethics and compliance with the law, and ensure employees understand that bribery and corrupt conduct is never acceptable.  Effectiveness of the compliance program requires top-level commitment by organisational leaders to implement a culture of compliance from the middle and the top[1].

  1. Adequate investment in people and capability:  The ABC program may be unsuccessful in practice if under resourced or not empowered to function effectively[2].  Sufficient human resources are required to effectively manage anti-bribery and corruption risks across all lines of defence.  The organisation must ensure that employees with ABC related roles are competent and experienced and have sufficient seniority and autonomy within the organisation. 

  1. Accountability for misconduct:  Effective implementation of the ABC compliance program requires the establishment of incentives for compliance and disincentives for non-compliance[3].  Appropriate disciplinary measures should be taken when an investigation confirms a violation of the anti-corruption laws or policy, otherwise doubt may be created about the organisations commitment to its values.

  1. Geographic impact on risk culture[4]: The countries in which the organisation operates may pose specific bribery risks, as measured by indices such as Transparency International’s Corruption Perceptions Index[5].  Some countries are known or perceived to be more corrupt than others, and as a result the bribery risk exposure can vary.

Have a look at our resources on bribery risk assessment on the Bribery Prevention Hub here: Management & Culture – Bribery Prevention Network

[1] United Kingdom Ministry of Justice Bribery Act Guidance issued in 2011 under section 9 of the UK Bribery Act (2010); Draft guidance on adequate procedures to prevent the commission of foreign bribery, Australian Government, Attorney-General’s Department accessed at

[2] U.S. Department of Justice Criminal Division, Evaluation of Corporate Compliance Programs (Updated June 2020), p9, accessed at

[3] Ibid, p13.

[4] Tuveson, M., Ralph., Alexander, K., Introduction, In Tuveson, M., Ralph, D., Alexander, K., ‘Beyond Bad Apples Risk Culture in Business’, p13.

[5] Corruption Perceptions Index 2021, accessed at