Despite progress, almost a fifth of employees say their company still has no formal anti-bribery and corruption policy in place, according to the 2018 Global White Collar Crime Survey, launched by global law firm White & Case, in conjunction with the University of Manchester.

Under pressure

The survey finds on third party risk, 40 per cent of legal and compliance staff feel pressure to approve engagement with third parties despite bribery and corruption risks. Middle management and internal compliance teams are the key to combating wrong-doing, with the survey finding that internal reporting structures are preferred, with 88 per cent most inclined to raise an issue internally. When asked whether their company has a formal ABC policy in place, 29 per cent of employees answered 'no' or 'don't know,' indicating that there was either no policy or no effective communication strategy around it. Respondents openly agreed that opportunities for bribery and corruption, as well as pressure to overlook risks, exist day-to-day. Darryl Lew, global head of White & Case's white collar practice, explains, ‘the survey results showing almost 40 per cent of legal/compliance personnel felt some form of pressure to approve third parties, despite potential red flags, emphasizes the need for strong management support for any compliance program to be truly effective.’

Tackling incentivisation

The research also revealed that perceptions around the benefits of bribery are still a key issue. Jonathan Pickworth, partner at White & Case, says ‘taking a closer look at how employees in high risk positions and jurisdictions are incentivised, and how their success and performance is measured, is key. Meeting compliance objectives and maintaining high standards of behaviour should be firmly linked to progression and financial reward, in a much more tangible way.’ Dr Nicholas Lord, reader in criminology in the school of law at the University of Manchester, comments ‘the study indicates that there is still a way to go – in terms of the development of internal compliance programmes and structure, and also in changing perceptions around the benefits and consequences of bribery and corruption.’ The full report can be viewed here.