The adoption of corporate compliance programs is the most important risk-mitigating factor when it comes to anti-corruption (no, a certification issued by a private entity is not the same, in case you were wondering).
Already in 1991, the Federal Sentencing Guidelines established the aforementioned principle, confirmed by the Sarbanes Oxley legislation in 2002.
Any anti-corruption training should be studied according to the specific challenges that the organization is likely to face and it should be aimed to achieve 3 goals:
It is not an easy task; ad hoc risk assessments need to be performed by means of enhanced due diligence (EDD), besides there are contractual clauses, accounting controls, audits and anti-corruption training (on this regard you may read about outr new training service We Are Preparing Due Diligence Training)
Anti-bribery policies, to be effective, must be widely diffused within the organization and specific training is crucial to verify that such skills have actually been assimilated and acknowledged.
Who Should be Subject to Anti-Corruption Training?
Anyone (potentially) able to obtain business. HR, procurement and finance departments( I am assuming the legal already is…)
Concerning the actual content of such training
Is it possible measuring the effectiveness of anti-corruption training?
Definitely not with absolute certainty, however, monitoring is an essential part of any compliance program.
Training should be performed on ongoing basis, in order to take into account legislative and regulatory developments as well as unforeseen challenges deriving from new markets, new business lines, extraordinary operations in furtherance of assets acquisitions etc.
In addition to the ones just mentioned, newsletters, questionnaires and workshops are useful tools to keep attendees engaged and seriously motivated in compliance (please don’t reward good attitude with bonuses Don’t Reward Compliance with Bonuses.
I will be speaking about these topics at the Global Compliance and Anti-Corruption Summit in Brussels next November.