As companies move into new markets, the risk for corruption grows. This requires anti-corruption learning solutions that are simple to implement and potent on impact.
Bribery Risk and Corruption Red Flags
The Corruption Perceptions Index (CPI) ranks counties based on how corrupt their public sectors are perceived to be. The latest rankings show that a full two-thirds of countries have a serious corruption risk. And, it’s not always in the countries you may think.
The U.S. Foreign Corrupt Practices Act and U.K. Bribery Act are two of the most broad and well-known anti-bribery laws, but almost all countries have some form of prohibition against corrupt business practices. Despite this, corruption remains prominent.
Fraud, bribery, exploitation and dishonesty may not always be completely straightforward to company compliance teams or their employees. Potential corruption red flags to look for include:
- Hiring an individual as a consultant who is related to a government official.
- Reimbursement of expenses without accompanying receipts.
- Requests for compensated travel or meals.
- Payments to out-of-country bank accounts.
- Donations to personal charities of government officials.
To make matters more complex, global operations are often delegated to third parties and other intermediaries. These intermediaries are critical to assisting businesses in bringing products and services to market, but also can pose the greatest area of bribery risk.
Even with assuming comprehensive due diligence, third-party intermediaries create nuanced relationships. These relationships decrease an organization’s span of control and generate compliance liability. To positively influence downstream business relationships, companies must focus on helping associates proactively identify corruption red flags and navigate these complex situations with clarity and confidence.
3 Things to Do Before Training
Anti-corruption training for third-party intermediaries may not look like traditional, in-house training. It requires incredibly streamlined information and enhanced accessibility. And, it will require native language content translation. But before rolling out a training program, consider these steps:
- Identify key risk areas. Consider specific situations, strategic business initiatives, regional market implications and opportunities and target account risks.
- Pull in legal guidance. Understand bribery laws, customs and privacy regulations that impact compliance guidelines as well as the way in which associates can be trained.
- Analyze third-party intermediaries you work with. Consider the way in which they work, your ability to communicate with them and their aptitude for digital training.
Third-party Intermediary Anti-Corruption Training Solutions
Third-party intermediary anti-corruption training and resources must be accessible, engaging, to the point and versatile.
Accessible: Anti-corruption training resources should be easy to access 24 hours a day, seven days a week in employees’ native languages. This ensures that third-parties can access it when they want to, not necessarily when you are available. One admirable goal of an anti-bribery training program is simply to get as many third parties to take it as possible. Accessibility ensures you start with a friendly reception. Don’t know where to start with translations? Consider using the six standard UN languages and further customizing content based on regional needs.
Digital resources and delivery will provide the greatest reach and ensure the most consistency in messaging. And, while learning management systems (LMSs) and internal intranets have many benefits for training company employees, they are a giant barrier to third-party intermediaries. Provide digital access to anti-corruption training outside of company firewalls if possible. Analysis of usage is often available through internet analytics tools or xAPI-based solutions.
Transparency in anti-corruption business practices to both business partners and government entities only increases the likelihood of compliant business transactions.
Engaging: Right away answer the “what’s in it for me?” Help third parties understand that while ethical and compliant business dealings may not be the norm, they allow for decreased time in company reviews, resulting in long-term trust from government authorities and minimal potential fines or contract terminations due to violations.
Consider compliance and potentially corrupt business transactions from the third-party’s point of view. What expense report information do they need? What business courtesies and meals are acceptable? Which are not? Who is considered a government official? How do they report concerns? Then, tailor your content around that information.
Anti-corruption training doesn’t need to be flashy. But it must be intuitive and visually appealing. Use modern visual design and professional audio. Consider infographics and video. Unique visual design techniques paired with exceptional instructional strategies have the ability to take what may be perceived by the third-party as dull compliance content and transform it to content that is saved, shared and used.
To the point: Third-parties do not need every policy the company has. They do not need the details of every country’s anti-bribery regulations. They do need streamlined and relevant content written in plain language. Wordy content with heavy legalese and numerous acronyms only leads to the abandonment of content.
Third-party intermediaries need to know what bribery looks like. What it sounds like. What it feels like. Only then can they recognize the red flags before they actually happen. Real-world scenarios and case studies bring potentially corrupt situations to life. Allow third-parties to put themselves into difficult situations. Make them (hypothetically) sweat a little in a safe and digital environment. When the training feels real, it will be remembered when it matters most.
Versatile: To ensure third-party compliance with anti-corruption guidelines, provide learning experiences in a variety of modalities. You can use anti-corruption eLearning peppered with interactivity and scenarios as a baseline, supplemented with on-the-job video reminders of country-specific compliant business practices and followed up with manager-driven coaching or instructor-led sessions for targeted situations.
Anticipate and allow for flexibility in training delivery based on what the third-party needs and wants. Perhaps a third-party manufacturer only allows for training at a specific time after lunch. Make your training available then. Perhaps another third-party distributor only needs an encouraging reminder for their field staff. Create an audio-only corruption case study they can listen to during their commute.
Third parties will vary in their understanding and application of anti-corruption principles and your learning experiences must meet them where they are. Regardless of the format, successful anti-corruption training consistently repeats that doing business ethically will always be right. Emphasize this and live it in every third-party intermediary touchpoint.
Strengthen Relationships and Minimize Risk
An effective anti-corruption learning solution puts responsibility and a sense of ethics and pride into the hands of third-party intermediaries. It encourages them to do business in alignment with company values and applicable laws and regulations. By ensuring third-party intermediary compliance, you not only strengthen business partnerships, but increase trust and transparency while minimizing exposure to risk.