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Anti-Bribery and Corruption

Prevent, detect, respond and remediate: Protecting your organisation against bribery and corruption

Bribery and Corruption are more prevalent in society than ever before. Worldwide justice systems are weakening, checks and balances are decreasing and conflicts rise -  allowing corruption to thrive. We support corporates and public sector organisations in preventing, detecting, responding to and remediating bribery and corruption to protect your organization, employees, business partners and society at large.

Organisations are taking action not only to comply with legal requirements and avoid reputational damage but because it is the right thing to do and is the only way to thrive as an organization in a world focused on ethics, sustainability and accountability. Implementing effective anti-bribery and anti-corruption (ABAC) programs is crucial in fostering a culture of integrity and accountability. By addressing the deeper, more insidious effects of corruption, organisations can contribute to building a fairer and more equitable society.

At Deloitte, we focus on these deeper societal consequences of corruption and understand the challenge of implementing an effective ABAC program. Our global network enables us to offer comprehensive solutions throughout the entire lifecycle of anti-corruption efforts. From advising on prevention strategies to providing a resilient response when bribery and corruption issues arise, we help protect your organization and prevent reputational damage. Our aim is not only to safeguard your organization but also to make a positive societal impact by addressing the root causes of corruption and promoting ethical business practices.

“Having a solid ABAC framework is not only key to protecting your organisation, but more importantly to contribute to a fair society.”
                                                      - Gerrie Lenting, Partner

 

Effective ABAC Compliance

 

To address the challenges of bribery and corruption, global regulators have intensified enforcement, emphasizing the need for rigorous ABAC compliance standards. Recent developments, including guidance from the United States Department of Justice (US DOJ), underscore the importance of effective compliance programs. Organisations demonstrating ABAC program effectiveness may receive more favourable regulatory treatment. Additionally, the US DOJ requires compliance programs to go beyond merely having policies in place, compliance programs must be dynamic and regularly assessed to ensure robust risk management.

An effective ABAC compliance program involves continuous evaluation of both internal and external bribery risks with periodic, informed assessments. This proactive approach allows organizations to effectively mitigate risks while aligning with regulatory expectations. Moreover, organisations committed to ethical practices benefit from such compliance, helping them navigate potential threats and contribute to a just and equitable business environment.

 

“Regulators around the world are constantly enacting more legislation on bribery and corruption, raising the stakes for your organisation. It is important to be prepared.”
                                                           - Ellen Bisseling, Partner

Effective ABAC Compliance

Our services

To help mitigate the negative effects of bribery and corruption and support your business in achieving effective compliance with global regulatory standards, Deloitte offers a range of specialized services. Explore our offerings below to see how we can assist in fostering a robust anti-bribery and anti-corruption framework. 

ABAC Risk Assessments

In the fight against bribery and corruption, understanding and mitigating risks is paramount. Deloitte Forensic's ABAC Risk Assessments provide a detailed examination of your organization's operations and transactions to pinpoint vulnerabilities to bribery and corruption. By evaluating both internal and external risk factors, we craft tailored strategies that enhance prevention and detection measures. Our robust frameworks and controls not only ensure compliance with anti-bribery laws but also strengthen your organisation’s ethical standing. Our adaptive risk assessment process evolves with emerging threats and regulatory changes, helping your organization to remain resilient and compliant.

Policies and Procedures

Developing effective policies and procedures is essential for any organisation to genuinely curb bribery and corruption. Merely having policies in place is insufficient; they must be proportionate to the bribery risks faced by the organisation and tailored to its nature, scale, and complexity. Our support in policy and procedure development ensures that these elements are fully addressed.

Third-Party Risk Management

Interactions with third parties are a significant source of bribery and corruption risks. Our Third-Party Risk Management services are designed to cover every aspect of the third-party lifecycle, from sourcing and contracting to ongoing monitoring and financial processing. We provide a comprehensive risk assessment system that safeguards your organization from potential bribery and corruption threats. By embedding integrity into each stage of third-party engagements, we help you make informed decisions, maintain compliance, and cultivate trust with partners and stakeholders.

Third-Party Risk Assessment

Deloitte Forensic's Third-Party Risk Assessment services focus on identifying and managing compliance risks associated with third-party relationships, particularly those related to bribery and corruption. Through enhanced due diligence services and comprehensive business intelligence reporting, we empower your organization to navigate and mitigate the risks that third-party interactions may present. Our approach ensures your compliance programs are robust and your business reputation remains protected against bribery and corruption threats.

Training and Communication

We assist organisations in embedding their policies and procedures effectively, ensuring that these practices are not only integrated into the organisational framework but also actively embraced by employees. Our training and communication strategies are designed to cultivate a culture where policies and procedures are consistently understood, adhered to, and reflected in daily operations.

Our training and communication support includes the following key aspects:

  • Tailored training programs: We develop risk based training programs that address the specific needs of your employees based on your organisation’s unique risk profile. Focusing on key areas such as compliance, ethical conduct, and operational procedures, these programs are designed to engage employees at all levels and foster a deeper understanding of organisational and regulatory expectations.
  • Interactive workshops and seminars: Our workshops and seminars are designed to be interactive, encouraging employee participation and engagement. This approach helps reinforce the importance of policies and procedures, making them relatable and applicable to everyday work scenarios.
  • Ongoing communication campaigns: We implement continuous communication campaigns that keep policies and procedures top-of-mind for employees. Moreover, this should also include regular communication about organisations’ position on addressing misconduct.
  • Leadership coaching and development: We provide coaching and development for organisational leaders to help them manage the risk of bribery and corruption. By empowering leaders to model and reinforce desired behaviours, we strengthen the overall organisational culture.

To ensure the effectiveness of training and communication efforts, we establish feedback loops and evaluation mechanisms. This allows you to assess the impact of your initiatives and make necessary adjustments to enhance employee understanding and compliance.

ABAC Transaction Testing

In the pervasive battle against bribery and corruption, transaction testing is fundamental in managing risks effectively. Recognising the intricate challenges organisations face globally, our dedicated transaction testing services are designed to efficiently scrutinise significant amounts of financial transactions, helping identify potential corruption risks and ensure effective compliance in line with ABAC regulations standards. This service is integral to fortifying your compliance programs by providing a robust mechanism to test and validate the effectiveness of your existing ABAC framework.

Our transaction testing approach is comprehensive and dynamic, crafted to align with both regulatory requirements and your organization’s unique risk profile. Through a systematic process, we engage in entity planning and risk assessment, followed by pre-fieldwork and fieldwork procedures. Our methodology includes advanced analytics and manual identification of high-risk transactions, ensuring a keen focus on high-risk areas.

Leveraging state-of-the-art technology and a team of seasoned practitioners, we work in tandem with your internal teams, including compliance, legal, and finance, to deliver insightful analyses and reporting. This rigorous process not only aids in detecting red flags and anomalies in transactions but also facilitates the development of actionable insights for improving your ABAC compliance program.

By choosing Deloitte’s transaction testing services, you are investing in a process that underscores transparency, accountability, and integrity, allowing your organization to mitigate risks effectively. Ensuring the effectiveness of your compliance program is not just about adhering to regulatory expectations—it is about fostering a culture of ethical business conduct that contributes to a fairer and more just society.

Reporting Mechanisms

Organisations must establish a robust system for employees to anonymously and confidentially report actual or potential breaches related to anti-bribery and anti-corruption. This involves implementing effective whistleblower and case management systems as a single repository, ensuring reliable and accurate management information on past cases and real-time updates on active cases. The focus is on verifying the effectiveness of reporting mechanisms specific to ABAC concerns and ensuring investigations are professionally scoped and monitored. By regularly analysing investigation findings, organisations can identify compliance weaknesses and enhance their frameworks. Providing clear guidance on compliance policies and implementing anti-retaliation measures, including training and incentives for reporting, are essential to fostering a culture of transparency and accountability.

ABAC Investigations

In a world of increasing regulation and technology-driven corruption, threats to your business's reputation are more prevalent. When bribery or corruption suspicions arise, swift investigations are crucial. Deloitte Forensic offers expert ABAC Investigations, enabling quick and confident responses to regulatory concerns and internal fraud probes. Utilizing our global network, advanced technology, and seasoned professionals, we assess situations and risk exposure efficiently. Leveraging the Deloitte Global Forensic Methodology, we uncover facts to support your organization in maintaining integrity and trust. With decades of experience, we provide holistic advice, safeguarding your brand and empowering you to navigate complex challenges confidently.

ABAC Framework Enhancement

ABAC framework enhancement supports strengthening anti-bribery measures following investigations into bribery allegations, completing the cycle from prevention to remediation. We address identified vulnerabilities, enhancing your ABAC framework with tailored strategies that reinforce compliance and ethical culture. By improving operations and transactions, we help your organization adapt to evolving threats and regulatory changes, safeguarding assets and ensuring resilience.