ABAC® team says no to corruption

On 31 October 2003, the General Assembly adopted the United Nations Convention against Corruption and designated 9 December as International Anti-Corruption Day, to raise awareness of corruption and of the role of the Convention in combating and preventing it.

We at ABAC® believe that merely “saying NO TO CORRUPTION” is not enough! We work at drawing attention to how different departments in an organisation can take action now and contribute towards the fight against bribery and corruption risks in businesses.

ABAC® supports our people, clients and partners in many forms, including conducting free educational seminars, publishing multiple thought leadership pieces and guides on anti-bribery, anti-corruption, risk and compliance management, certifying and training businesses worldwide on anti-bribery, anti-corruption, and risk management.

We aim to highlight that it’s everyone’s job to contribute towards ethical and transparent business relationships. We would like to encourage every department within organisations to recognise that they could improve their daily business operations, which could help promote more transparency and compliance. It’s everyone’s responsibility, and corruption is everyone’s problem – we need to give our employees the tools they need to recognise, detect and report bribery, corruption or any other illegal behaviour.

Together with our parent organisation (CRI® Group), ABAC® offers the ethics and compliance hotline – a tool designed to help employees, as well as clients, contractors, vendors and others in a business relationship with us. We invite you to report any illegal, unethical, or improper behaviour on the hotline now!

ABAC® team speaks against bribery and corruption

ABAC® interviewed team members working in areas of ABMS auditing, ABMS training, compliance, operations, human resources, finance, business development, marketing, information security, and investigations about their daily fight against bribery and corruption. The interviews below will give you valuable industry insights directly from our experts:

• Huma Khalid, Global Scheme Manager | Dubai, United Arab Emirates
• Soraia Antunes, CMO | London, UK
• Faisal Shamraiz, IT | Dubai, United Arab Emirates
• Raees Ahmed, BD | Islamabad, Pakistan
• Melody Brown, Accounts | Dubai, United Arab Emirates
• Ashelea Arsadon, Manager Investigations | Dubai, United Arab Emirates
• Nor Hidaya, Operations | Kuala Lumpur, Malaysia
• Nilofar Gardezi, HR Director| Islamabad, Pakistan

Q: How are you/your department fighting bribery and corruption daily? 

Huma Khalid: As a Scheme Manager, my core responsibility is to ensure impartiality in delivering audit and certification services. For every client, I undertake a risk assessment, in which financial impartiality is one aspect. When appointing and delegating the audit team, I ensure that all members are aware of the anti-bribery and anti-corruption policy and act objectively and ethically throughout the audit process.

Nilofar Gardezi: Corruption and bribery can affect all aspects of HR processes. The main risk areas which I as an HR professional see is nepotism and abuse of authority which can come in a way of talent acquisition, training, promotion and appraisals. So accountability, transparency in processes, a stringent check & balance mechanism in the processes is required in order to have effective internal controls in all HR processes to avoid bribery and corruption at all levels of HR activities.

Raees Ahmed: I make sure everyone in my team follows the SOPs and policies and executes tasks with honesty, following the professional ethics and norms.

Faisal Shamraiz: We follow ISO 37001 guidelines on a daily basis, and we have very strong monitoring controls in place. Overall, processes and activities in the Information Security Department were reviewed by the Independent Department. This International Standard helps us prevent, detect and address bribery by adopting an anti-bribery policy, appointing a person to oversee anti-bribery compliance, training, risk assessments and due diligence on projects and business associates, implementing financial and commercial controls, and instituting reporting and investigation procedures.

Ashelea Arsadon: I also ensure that I and my team members follow the code of conduct and perform our tasks with integrity, diligence and follow the set standards and procedures.

Nor Hidaya: We have standard practices that we follow at the workplace to keep the organisation bribery- and corruption-free. We have clear protocols that set the clear standards and guidelines in the workplace, and open communication within the workgroup. Business owners and managers encourage a general sense of communication that let employees have an understanding that it is easy and simple to approach when we have concerns. Also, we encourage oversight in financial transactions and practice a proper whistleblowing policy within the group.

Melody Brown: In the finance department, the risk of bribery is mostly associated with unauthorised payments to internal officials and third-party vendors. When financial controls are not in place to verify the purpose of payment, then the risk of bribery will increase. At ABAC® we follow this practice in order to reduce the risk of bribery. In my opinion, all finance professionals should ensure that all third party invoices and payments are crosschecked to an authorised contract and for the legitimate services. If the third party does not provide adequate justification for the services then the company should withhold the payment until complete information is provided.

We invite you to join us in the fight against fraud. Help us by answering questions about what actions you take when fighting bribery in your organisation and operating regions. Participate in our short survey and get the chance to win a Gap Assessment for your organisation (worth USD 4500)!

Q: What advise would you give other professionals in your field with regards to anti-corruption awareness and compliance management? 

Huma Khalid: Companies tend to do cost-cutting in the development and training of employees, especially when it comes to non-technical matters. However, under the principle of Corporate Liability, there is the corporation’s legal responsibility for actions undertaken by the company itself or its employees (or agents working on its behalf), that could be considered unlawful.

Nilofar Gardezi: I would advise the HR fraternity that usually when we talk about corruption and bribery, most organisations direct the focus to their compliance and legal personnel. But HR professional should make themselves aware of anti-corruption policies in their domain because corruption is not always referred in terms of monetary terms – there are non-monetary corruption practices as well. For example, if you are hiring someone who is not matching the competency criteria of a job but is a relative of the board member then this is a form of corruption. Similarly, if you are providing professional development and training opportunities to an employee who is not even relevant to the training based on TNA conducted, but he/she has been provided with a training opportunity only because he/she is in good terms with HR or management. This is corruption.  This could be avoided by having strict internal controls and processes. Also, one message that I really want to convey to my fellow HR fraternity members is that apart from compliance team, HR should also provide awareness of whistleblowing and complaint management procedure on a frequent basis and encourage employees to highlight any corrupt practices in the organisation without any fear. It is largely observed that employees who observe corruption or are forced into such a situation usually stay quiet because of a fear of losing their job. So, if we have strong procedures in place ensuring anonymity of a whistleblower then as HR professionals, we can also play a major role in fighting corruption in the organisation.

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

Faisal Shamraiz: I would suggest that organisations must have ISO 37001 Anti-bribery Management System Standard in place, as this is a great tool to implement anti-bribery and anti-corruption procedures.

Ashelea Arsadon: Bribery and corruption are deep-rooted in businesses and daily life and masked as routine, so there is an immediate need to develop awareness about how bribery and corruption schemes can manifest themselves and take preventive action to counter these risks. There is also a need for a strong reporting mechanism in place to ensure that the incidents taking place are being reported, investigated and resolved.

Nor Hidaya: We conduct business lawfully and ethically around the world. Understanding anti-corruption laws and promoting a culture of compliance, and its implications help us do that. In my opinion, other organisations should do the same. There are few simple steps to promote anti-corruption awareness and compliance management, such as senior management’s commitment towards anti-corruption & compliance management; having effective standards and controls, which derives from the culture of compliance; frequent communication from senior management reminding employees of the importance of anti-corruption compliance; regular compliance training and ongoing monitoring & auditing.

Melody Brown: The culture is ultimately set by the tone at the top, whether that be senior management or head of departments who regularly talk about ethical issues, support staff to uphold the ethical standards, and behave in an open and transparent way, send the message to all employees, that the fight against corruption is taken seriously. If senior management declares a zero-tolerance approach to bribery and corruption, they must demonstrate that they will support that even if it comes to losing contracts. We have to create a culture of integrity and openness where ethical dilemmas arising from the business in corruption are properly discussed with the employees and they must feel supported to do the right thing. This is a powerful way to help mitigate the risk of an ethical lapse.

Q: Have you ever encountered bribery and corruption or been offered/requested a bribe? What actions did you take, how did you report it?

Huma Khalid: No, I have not encountered a situation where I have been offered a bribe. However, if this situation was to arise, I will report it to the Managing Director.

Nilofar Gardezi: I personally did not encounter any bribery and corruption scenario, but a friend of mine who is also from HR fraternity faced a situation where the team of consultants were paid bonuses annually subject to their project success from a project’s budget. When the bonuses were approved by HR and were passed onto accounts department for review and disbursement, an accounts staff asked the consultants to transfer a certain percentage from their bonus amounts to him/her, to have the bonus released. The consultants resisted and complained to the HR representative, who reported this to senior management. Unfortunately, one member of senior management was also involved in this and the consultants lost their bonuses, thus paying the price of their ethical and moral values.

Raees Ahmed: Luckily, I have never encountered such a situation. If I will ever face such an issue, I’ll follow the whistleblowing policy.

Faisal Shamraiz: Information security personnel are the key assets of any organisation. They are always at high risk because they have access to all confidential information companies are dealing with. If they were bribed, they may provide all the confidential information to the competitors or other people who attempt to damage their organisations. This type of bribery is faced frequently – there are many organisations and/or individuals who approach information security teams and offer us huge amounts of money or dream jobs in return to desired confidential information which we have.

Luckily in our organisation, we have ISO 37001 guidelines in place and our processes are very transparent. When we find any suspicious activity like this, we raise it to the relevant department as per our processes and procedures.

Ashelea Arsadon: During client interaction at site visits, I have never encountered any situation which can be categorised under bribery. But let’s suppose I face such an incident – my immediate response would be declining the offer and reporting it to the compliance officer.

Nor Hidaya: Luckily, I have never experienced bribery/corruption in the corporate level, but once I had to report the police officer to his superior in charge as the policeman was seeking bribes.

Melody Brown: No, we haven’t experienced this before. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. In future, if we will face any such situation, we will surely report that and take action.

Q: In your opinion, what is the biggest risk with bribery and corruption?

Huma Khalid: Bribery and corruption cause far-reaching impact and manifest themselves in multiple forms. Let’s take the example of a common form of corruption in workplaces which is nepotism. Perceived favouritism and unfair hiring/promotion cause dissatisfaction and low morale among employees which in turn leads to demotivation to perform and loss of productivity. Such employees may also feel they are “above the law” and engage in abusive behaviour or corruption schemes with an assurance of having top-level support and not being caught or monitored. On the other hand, employees who feel unjustly treated may seek other forms of compensation and engage in other corruption schemes. Such actions can result in financial liability for the company. What appears to be harmless at first and granted as a favour may have far-reaching consequences in the long term. 

Nilofar Gardezi: The major risk associated with bribery and corruption whether at an organisational level or individual level is reputational damage. In regions where there are regulatory compliance guidelines against corruption and bribery, guilty organisations or individuals could be penalised with hefty fines.

Raees Ahmed: I would list the following major threats: reputational damage in the market, negative publicity, negative impact on prospects, damage of trust.

Faisal Shamraiz: If any organisation or its employees are bribed, the organisation’s reputation might be highly damaged. It also will face huge fines. This is not worth the risk!

Ashelea Arsadon: I would highlight these risks: reputational damage, imposition of fines by regulators, negative media exposure, loss of clientele and an overall loss of trust.

Nor Hidaya: I would say, corruption increases the cost of education in countries, where bribery and connections play an important role in the recruitment and promotion of teachers. As a result, the quality of education decreases and this affects the overall health of the economy worldwide.

Melody Brown: The biggest risk associated with bribery and corruption is the reputational damage. If any individual gets involved in bribery and corruption, it will impact the entire brand image. Other risks can be financial loss, negative effect on employee morale, increased scrutiny or criminal charges.