Global Anti-Bribery Guidance

Aim: To develop an integrated approach for internal communications, training and engagement to support and facilitate the company’s anti-bribery commitment.

Internal communication and training have traditionally been the main ways in which companies can convey the anti-bribery policy and programme to all employees. Now, companies are recognising the value of taking a comprehensive and integrated approach to employee engagement.  An integrated approach brings together all aspects of engagement with employees across their activities with the company.

Internal communication, such as general communications, promotional materials and targeted campaigns, provides employees with essential baseline information on the company's anti-bribery commitment while also raising awareness and understanding of the anti-bribery programme. A wide range of channels can be used including: websites, intranet, social media, mobile technology, postings on bulletin boards or walls, handbooks, employee manuals, newsletters, employee meetings, suggestion schemes, advice and helplines. The content and language of communications should be adapted to reflect varying audiences, localities and countries.

The anti-bribery programme and related messages can be communicated by line management and this should also enable discussions on key issues. Feedback and concerns voiced at discussions should be noted and provided to the compliance function in order to contribute to improving the anti-bribery programme. The approach should be to build the trust and confidence of employees in their right and access to voice and discuss concerns on anti-bribery issues with management.

In the first instance, the aim of the company should be to encourage employees to raise matters with their line manager or the compliance or ethics officer. This may be supplemented by giving the employees the right and protection to enable them to use a ‘leapfrog’ approach where they can jump management levels to voice and discuss concerns in situations where they are not comfortable speaking to their line manager. Regular opportunities should be provided to enable employees to engage in free and open discussion in relation to the anti-bribery programme and potential risks of non-conformance. This can be through online training

Basic training on the anti-bribery programme should be given to all employees and board members, most likely as part of wider training on the company’s code of conduct. In addition, dedicated, and tailored anti-bribery training should be given to those in high-risk functions.

Training should provide an understanding of what constitutes bribery, while also providing information in relation to improper practices and likely risk areas. It should aid recognition of how bribery demands take place and set out how to respond. The training should ultimately support the development of skills to avoid or resist demands or solicitation for bribery. The training should also build employees’ confidence and trust in, and commitment to, the integrity of the company. In this way, the company can encourage employees to act as ‘integrity ambassadors’, representing and promoting the company’s commitment through their actions.

The delivery of training can be facilitated through a range of training methods including: intranet, remote e-learning, external courses, seminars and conferences, and publications and training materials. Face-to-face training is vitally important as it communicates directly the company’s commitment, the significance of bribery risks and how to counter them, and is much more effective than remote e-learning. This can be delivered by either internal or external trainers. It is also important as it provides employees the chance to discuss topics and concerns with well-prepared instructors and experienced managers.  The employee discussions can also contribute to the improvement of the anti-bribery programme. Suggestions and concerns should be captured and fed back to the compliance function. Employees should then be assessed at the culmination of the training (for example, by a multiple choice questionnaire) so that they can demonstrate their understanding.

Courses and other training delivery methods should also be evaluated to test the quality and value of the content, and whether it has led to any substantive changes in the way employees operate. This may be difficult to measure but feedback should be gained from managers as to whether they have seen any evidence of changes. The delivery of training should also be monitored and documented.   The employees’ personnel files should be updated to record their attendance at the training and a process should be put in place to ensure that they receive regular refresher training.

Free online training for SMEs

The costs of anti-bribery communications and training may seem prohibitive for SMEs but there are ways of reducing the cost. This can be by focusing activities on the areas of highest risk, and using communication and training techniques such as video and interactive media. Larger companies, particularly clients of SMEs, may be able to provide support.

Transparency International UK has also provided a free online training resource, available at http://www.doingbusinesswithoutbribery.com/ This free 1.5 hour online learning module provides comprehensive anti-corruption training designed by leading experts in the field, and enables organisations to provide training for all their personnel.

Training should also be provided to board members. This will be designed to reflect their fiduciary and statutory responsibilities and is vital in order to enable them to have the skills and knowledge to carry out their role in providing leadership, addressing risks, building the company’s culture of integrity and governance and providing tone from the top. At the same time, the training will need to be sensitive to the time demands on board members while also being conscious that they may be over confident about their knowledge on these training topics.

Board training content can include:

• The external environment for anti-corruption including changes in legislation, recent cases (including fines) and emerging trends.
• The aspects of the main relevant laws, including any personal liability.
• Related statutory responsibilities of directors.
• High-level discussion on topics such as integrity culture, B20 and other inter-governmental initiatives.
• Independent assessment role of the board and its committees.
• How the company culture is managed and assessments of its status.
• The implications of the company’s risk approach.
• The risk assessment methodology.
• The results of assessments.
• The key identified risks and any residual risks.
• How risks are mitigated.
• The methodologies for reviews and audits and the results.
• Specific aspects of the anti-bribery programme elated to directors’ activities including conflicts of interest, the ‘revolving door’, gifts, hospitality and expenses, lobbying.
• Where to seek advice.

‘At Intel innovation is core to everything we do; our Ethics & Legal Compliance team strives to inspire our employees through cutting-edge educational programs.’

Jo Levy, Chief Compliance Officer, Intel, 2016.

Intel arranges anti-corruption communication campaigns around International Anti-Corruption Day. In 2015, this engaged an employee population of approximately 110,000 with a multi-day campaign designed to empower employees to take a leadership role in the conversation about bribery and compliance. The program leveraged journalism, social media, employee-generated content, gaming and peer-group participation for immediate feedback and to socialize learning.

‘Ethics and Compliance Business Champions serve as the liaisons for the Ethics and Legal Compliance group in business groups and sites across the company. They are responsible for advocating and monitoring ethics and compliance, helping drive corporate initiatives, and serving as local experts.

The 2015 anti-corruption awareness campaign included an online selfie contest open to all employees and generated over 20,000 unique views. The company arranges an Ethics and Legal Compliance Group speaker series and a newsletter which serves to educate Champions on trends in areas such as conflicts of interest, privacy and security, antitrust, insider trading, product regulations and standards, anti-corruption, and export compliance. Through an Intel Ethics and Compliance Excellence Awards program, launched in 2010, the company regularly recognises teams and individual employees for their contributions to ensure Intel’s ethical and compliant environment. In 2015, five teams and individuals received the award. In addition, as part of an internal employee recognition program, employees regularly honour their peers for role modelling Intel values. Each quarter, thousands of employees recognize each other for demonstrating uncompromising integrity in their day-to-day work at Intel.’

Intel Corporate Responsibility Report 2015

‘We want to maintain a culture where employees do the right thing automatically, not just because they were told they have to or because they are afraid of potential consequences. Employees across the Group receive regular communications, online refresher training, face-to-face sessions and team briefings on various aspects of our compliance programme, depending on their role. The Code of Conduct learning and awareness programme, Doing What’s Right, is designed to help employees across the Group understand their responsibilities to our people, partners and shareholders. Through this programme, employees complete e-learning courses every two years on the Code of Conduct, anti-bribery, privacy, competition law and customer data security. Line managers attend face-to-face briefings from our senior leaders on the key topics of Vodafone’s Code of Conduct and their role as a people manager.

The Doing What’s Right programme is rolled out to new employees as early as possible when they join Vodafone, so that they are clear on our standards from the start. This applies to employees joining us through acquisitions as well as new starters.'

Communication and training: 'Our anti-bribery policy is included in our Code of Conduct and promoted on a dedicated intranet page with clear and concise guidance. It is supported by a global training and communication programme that includes an anti-bribery e-learning tool available to all employees. Face-to-face workshops in all our markets help to ensure that employees working in higher-risk areas (such as procurement, enterprise and government relations) have a practical understanding of the key issues. In 2014/15, our global Doing What’s Right programme included communications on our Code of Conduct and offered additional training for line managers on our main policies, including anti-bribery. To promote further engagement with our policies, we maintain a community webpage on our internal social media site, Circle, which allows users to post short updates and links to useful documents and websites and to seek advice where required.'

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Effective anti-bribery and corruption training must resonate with staff. Employees need to understand what anti-corruption means and why it is important, and to make a personal commitment to behave in an ethical way.

As the world’s leading anti-corruption NGO, TI-UK has been fighting corruption globally for more than 25 years and has a special insight into the impact of corruption on economies, societies and ordinary people’s lives. TI-UK provides its experience and expertise to companies either as part of in-house staff training programmes or through stand-alone training courses.

We can assist you with general and tailored anti-bribery and corruption training

General anti-bribery and corruption training

For example:

• Staff training sessions, such as training for sales staff or inductions for other staff who might be exposed to corruption risks in their line of work
• Talks at staff conferences or team building events to help build awareness of the importance of countering bribery and corruption

Tailored training

Expert perspectives can be given on a range of topics, such as:

• Using agents and intermediaries
• Managing supply chains
• Performing due diligence for mergers and acquisitions
• Developing Adequate Procedures to comply with the UK Bribery Act

Typically, the specialist training courses are aimed at:

• Compliance teams, within organisations of all sizes and across all sectors
• Corporate affairs
• Senior and expatriate management

For more information on courses or to discuss training requirements, contact training@transparency.org.uk.