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

On 15 September 2022, the US Department of Justice released additional guidance around its corporate criminal enforcement policies. The guidance reinforced the DOJ’s commitment to corporate criminal enforcement and contains several important takeaways for companies, particularly with respect to the evaluation of compliance programs, including: a continuing focus on individual accountability and expectation that companies Continue reading

The footprint of your company’s operations in perceived high bribery risk locations is an inherent risk factor to consider when documenting your bribery risk assessment.  The overall environment present in each jurisdiction can increase the level of bribery risk.  Some countries are known or perceived to be more corrupt than others, and as a result, Continue reading

Self-reporting is a significant first step in addressing suspected bribery. Self-reporting can help to limit corporate criminal liability and protect your business’ reputation. There can also be requirements to report to regulators, the ASX and other entities. In Australia, the recent foreign bribery case of R v Jacobs Group demonstrates how courts may take a Continue reading

The June update from the Bribery Prevention Network is here. This edition includes a note from Departing Steering Committee Member, Serena Lillywhite AM. Read the full June update here. Continue reading

The OECD is currently seeking responses to the following surveys on anti-corruption prevention and awareness-raising with private sector stakeholders. The responses will assist the OECD in ensuring its studies, findings and recommendations are relevant and useful to the private sector – particularly in respect of companies doing business offshore.  These surveys are entirely voluntary and Continue reading