ESG Metric: Anti-corruption
Ease of implementation: Medium
Suitable for: All businesses
Suggested functional lead: HR, legal department
Summary
Reporting a corruption incident demonstrated your company's commitment to tackling corruption and work towards an anti-corruption policy. To report an incident, it is crucial to understand what information is necessary to fully assess the situation. With the gathered information, you can set up way employees can report an incident, such as a Google Form. Ensure it remains simple and to the point. Once a report has been submitted, a member of staff must investigate and monitor the case, collecting as much information as possible from other sources. If a conclusion cannot be made in house, you can get further support from government organisations such as the Serious Fraud Office (SFO) in the UK.
Background Information
Corruption is defined as “requesting, offering, giving or accepting directly or indirectly, a bribe or any other undue advantage or prospect thereof, which distorts the proper performance of any duty or behaviour required of the recipient of the bribe, the undue advantage or the prospect thereof”1. Corruption and bribery are responsible for an average direct annual global cost of $3.6 trillion paid in bribes annually2. Thus, anti-corruption legislations are being enforced more rigorously globally to ensure all business, whether private or public, are being held accountable. Notably, the Foreign Corrupt Practice in the US and Bribery Act in the UK are making companies more liable for the conduct of their employees and the actions of their intermediaries including agents, consultants and other external parties.
Implementation Steps
What information do you need
It is important employees are as detailed as possible when reporting on a possible corruption case. As a minimum, it should include: what happened, who was involved, where did it occur and when, suspected reason why it occurred and how it happened. This information should remain anonymous and only accessible to an investigator and head of auditing.
How to report the information
Set up the best way for employees to report on corruption. This may be via a Google Form or directly through email, telephone, or directly contacting a member of staff. Any forms should include these questions:
What do you wish to report?
Where did it take place?
When did it take place?
How did it take place?
Option to add documents
Options to remain fully anonymous, anonymous to everyone but the investigator or happy to prove personal details
Monitoring the information
The investigator, either internal or external, should analyse the report and make a preliminary assessment based on any supporting documents. They should investigate further and to prove or disprove the allegations. This may include collecting other documents, testimonials, electronic devices and other evidence.
Report externally for further support if necessary
The Serious Fraud Office (SFO) by the UK Government outlines a straightforward reporting system regarding serious fraud, bribery and corruption. The online form initially requests whether you would like to report online fraud, economic criminal activity, corruption and more. When selecting the corruption option, the SFO outlines information of the reporting process and how your report will be stored securely and anonymously. At the bottom of the page, there is a link to the Secure Reporting Form, also linked here, where you will be asked a series of questions regarding the case. The team will then be in touch regarding further steps.