Getting Started

I suspect bribery and corruption in my business and supply chain – what do I do now?

Thoroughly investigating actual or suspected incidents of bribery is critical.

Thoroughly investigating actual or suspected incidents of bribery, including within your own organisation, is critical, and will help you meet your legal obligations, to report to regulators and stakeholders in a timely fashion, and to identify and fix weaknesses in controls and systems. Whistleblowers can play a key role in identifying bribery. Supporting and protecting whistleblowers demonstrates 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.

Relevant resources

There are many layers to remediating bribery and corruption issues, including: identifying root causes, addressing weaknesses in systems and processes, imposing consequences on the people who have done the wrong thing, putting commercial relationships onto the right footing and paying reparations where appropriate. This incident response map works through some of the key issues related to a remediation response.

When allegations of fraud or corruption arise, it is important to undertake a prompt and thorough investigation. This short 'how to' guide outlines the key steps to make an investigation effective. Be sure to also consider the 'whistleblowing' section of this site for more recent developments in obligations relating to whistleblowers.

Self-reporting is a significant first step in addressing suspected foreign bribery. This Guideline is designed to provide companies with information about how self-reporting will be taken into account by the CDPP when determining whether or not to commence a prosecution, and highlights the reasons why a company may choose to self-report including to comply with directors’ duties and limit liability. Information about early guilty pleas is also provided.

Whistleblowers play an important role in detecting bribery and corruption. To encourage whistleblowers to come forward and report misconduct, Australian law affords whistleblowers certain rights and protections, which will impact on how any investigation into a report is conducted. ASIC has published guidance to help companies understand Australian laws concerning who is a whistleblower and how they are protected.

Suspected bribery of foreign public officials can be reported to the Australian Federal Police (AFP). This fact sheet tells you how. Companies that discover foreign bribery and do not report to the AFP may face increased liability for maintaining a corporate culture that tolerates bribery. Companies that report their own conduct can receive discounted penalties (and may not be prosecuted at all).

A resource to help develop an understanding of how internal reporting mechanisms can strengthen a business. Provides guidance on the components required for a business to have effective reporting mechanisms and early detection. Covers the benefits of whistleblower reporting mechanisms and having employees speak up about legal or ethical misconduct.