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: 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

US Department of Justice releases new guidance on corporate criminal enforcement

Posted on September 15, 2022

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

Inherent factors to consider in your bribery risk assessment

Posted on September 14, 2022

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

Recent foreign bribery case highlights importance of self-reporting

Posted on September 9, 2022

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

June BPN Update

Posted on June 21, 2022

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

Voluntary OECD surveys seeking input on anti-corruption compliance

Posted on March 28, 2022

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