UK Bribery Act: what next?
The UK Bribery Act came into force on 1st July 2011, and as a result the UK now has one of the most stringent anti-corruption regulatory regimes in the world. What should organisations now be doing to ensure they develop and maintain a fit for purpose anti-bribery and corruption programme?
Although we have yet to see a corporation prosecuted under the UK Bribery Act, it is evident from recently settled cases at home and overseas that preventing bribery and corruption is certainly front of mind for the UK authorities. We are seeing many companies implement changes and enhancements to policies, procedures and processes to enable them to demonstrate adequate anti-bribery and corruption procedures. That said, we note that many organisations have yet to respond fully to the changing legislation and remain vulnerable as a result.
How Deloitte can help
Our anti-bribery specialists at Deloitte have helped some of the world’s highest profile organisations implement bribery and corruption procedures. From our detailed appreciation of what it takes to implement an anti-bribery programme, and our analysis of the MOJ guidance we have the capability to assist your organisation in developing adequate procedures including:
We can support your organisation in the performance of your risk assessment including performing both individual unit risk assessments and organisation wide assessments. Our risk assessment methodology is highly flexible to your organisation’s circumstances and explores all of the dimensions that the MOJ have highlighted.
Supporting you in defining and delivering action plans to develop your anti-bribery procedures, we can:
- analyse the areas where the balance of risks and controls merits further anti-bribery procedures to be put in place
- provide you with expertise and advice in relation to the delivery of your anti-bribery programme
- identify elements of good practice to inform your anti-bribery procedures.
Anti-bribery and Corruption training
We have a range of training solutions that are in whole, or in part, capable of meeting the needs of your organisation including:
- Awareness training (targeted for general distribution)
- Case study examples (for those seeking enhanced understanding)
- Practitioner training (targeted for those in high risk roles)
- Top level management training
- Board training
Our Enterprise Risk Services practice has significant experience of developing and testing control frameworks for ethical and regulatory compliance. Working with you, we can use our knowledge, skills and expertise to define and deliver tailored testing programmes for your bribery prevention controls.
Business Intelligence Services
Our Business Intelligence team are able to obtain information relating to the background and reputation of potential joint venture partners, sales agents or other business partners who may fall into the definition of associated parties.
Forensic Data Analytics
Our Forensic Data Analytics team has a number of relevant tools and techniques which are used to assist clients in their anti-corruption efforts. These include:
- Data mining and interrogation capabilities that can highlight potentially problematic transactions quickly and efficiently
- Online survey tools that can quickly gauge the state of awareness of staff with a company’s anti-corruption policy and related procedures and controls as well as highlight potential corruption risk areas.
Transactional Due Diligence
Our corruption specialists have worked with both buyers and sellers to identify corruption risks as part of the due diligence process. The results of such work can influence deal price and also allow acquirers to mitigate identified corruption risks both pre and post acquisition.
Our corruption and forensic accounting specialists have deep experience of conducting investigations and producing reports that are responsive to the needs and expectations of regulators and enforcement authorities.