Anti Bribery and Corruption Audit Checklist

Maintain and communicate an anti-bribery policy as well as keeping detailed records of gifts offered, accepted, or declined.

Central Government departments and their trading arms can be vulnerable to bribery and corruption. This checklist, adapted from the MENA FCCG Technical Working Committee questionnaire, can help protect against these risks.

1. Conduct a Risk Assessment
Assessing the risks of bribery and corruption will enable an organisation to identify areas of weakness, focus its resources, and determine areas of vulnerability. As part of a larger fraud risk evaluation, this exercise should use a risk matrix for prioritisation purposes; its review should occur regularly as your anti-corruption strategy develops.

An anti-bribery and corruption risk evaluation could involve a company in the construction industry, where one of the primary forms of corruption involves gifts from contractors. According to The Chartered Institute of Building’s recommendations, companies should assess risks from contractors by identifying who might be corrupt and reviewing whether any gifts have been given or received.

An effective way of raising awareness of bribery and corruption among staff members is ensuring they all receive appropriate training. One such course, available across Government departments on the Civil Service learning portal titled Counter Fraud, Bribery and Corruption can do just this.

2. Conduct an Internal Audit
Are procedures in place to detect and report suspected instances of bribery and corruption promptly? Ideally this would form part of the fraud and whistleblowing reporting system, but alternatively it may exist as a separate mechanism accessible to all staff and managed by an appropriate senior counter corruption champion?

Central Government employees hold unique responsibilities and access to sensitive material such as state secrets and commercially confidential material, making them particularly susceptible to bribery and corruption than their counterparts in the private sector.

Therefore, it is of vital importance to maintain an effective culture of integrity and accountability. A key measure to achieve this goal is ensuring staff understand their risks and responsibilities through training; best practices include disseminating antifraud/bribery e-learning available on the Civil Service learning portal across all levels of staff in order to build knowledge about risks, issues, responsibilities and foster an effective antifraud culture.

3. Conduct an External Audit
Though companies frequently prioritize third party risk, most FCPA settlements involve corruption that occurred internally or through associates. Within an organisation with multiple departments and teams across locations and multiple communication gaps between teams and locations, misaligning processes, communication gaps or compliance fatigue may cause staff to ignore corporate integrity standards in favor of meeting business objectives.

Anti-bribery and corruption strategies should be championed by senior managers to ensure the message spreads throughout an organisation. This may involve designating a senior counter corruption champion or creating a role (such as Counter Fraud Champion) with responsibility for promoting it within another function (for example Audit, HR, procurement). It is vital that this person works closely with his/her teams so they are communicating these messages directly to respective stakeholders.

At a minimum, it is critical that you periodically review the anti-bribery and corruption procedures of all outsourced service providers – this should include gifts offered, accepted or declined; hospitality events; as well as safeguarding high-risk data sets. Doing this will increase accountability from external partners while simultaneously helping identify risks and encouraging them to work alongside you to address potential bribery or corruption concerns.

4. Conduct a Compliance Review
Central Government departments face the threat of bribery and corruption as they exercise significant influence over large groups, have access to sensitive data such as state secrets or commercially confidential material, and can become attractive targets for those attempting to corrupt. It is therefore imperative that they protect themselves and those they work with by implementing robust anti-bribery procedures.

Be sure that service providers, like IT suppliers, undergo appropriate screening measures, with a gift and hospitality register being put into effect to record any offers made or accepted by staff. Furthermore, an effective policy must exist for screening all employees and contractors of an organisation.

Assess the content, delivery, and update of anti-corruption training provided to all staff. In addition, take note of whether senior managers have encouraged or discouraged compliance as an effective means of meeting business objectives.