When you think of bribery, you might think of bent coppers (thanks, Line of Duty). Or, you might imagine shady political deals and cash-lined handshakes.
The reality for the vast majority of businesses and organisations, however, is much more prosaic – though no less insidious. Bribery is, in fact, extremely commonplace. Why? Simply because many employees don’t know a bribe when they see one.
As such, anti-bribery training is required to reduce the risk that someone who works for you or on your behalf might be exposed to bribery.
Oddly, despite bribery being a common cause of corruption, many organisations do not train staff to be aware of what situations and actions they should be avoiding. This leaves them exposed to non-compliance and regulatory or legal action.
The compliance aspect of bribery comes via The Bribery Act 2010, not only says that commercial organisations should adopt a “risk-based approach” to managing bribery risks, but also includes training as one of its six principles.
In this blog, we’ll reveal what you need to know about anti-bribery training so you can figure out if your organisation needs it and what to do next.
What is anti-bribery training?
Anti-bribery training educates staff about bribery so they can recognise it and make the correct decisions when they encounter it.
There are two core learning outcomes with anti-bribery training:
- Being able to recognise the many forms of bribery
- Being able to react/respond to bribery attempts correctly
It’s important for everyone in an organisation who might be exposed to bribery to receive anti-bribery training so there are no weak links.
The Bribery Act 2010 defines bribery in law and any good anti-bribery course should help people understand the intricacies of the legislation.
What are the six principles of the Bribery Act?
The Bribery Act 2010 has six principles. They are not prescriptive but are designed to guide and inform decisions regarding anti-bribery policy.
Principle 1
Proportionate procedures
Put in place procedures that are proportionate to the scale and complexity of your commercial organisation’s activities.
Principle 2
Top-level commitment
Foster a top-level culture within your organisation that takes bribery seriously and makes it clear that bribery is not acceptable.
Principle 3
Risk assessment
Assess and understand the risks of bribery posed to your organisation and the persons associated with it.
Principle 4
Due diligence
Take a proportionate and risk-based approach to bribery in respect of procedures and the persons who might be exposed to bribery.
Principle 5
Communication (including training)
Ensure that your bribery and prevention policies are understood within your organisation with training that is proportionate to the risks you face.
Principle 6
Monitoring and review
Keep on top of your bribery policy and procedures and make improvements where necessary to assure continued compliance.
You can find more detail about the six principles of the Bribery Act here.
Who needs an anti-bribery policy?
Every commercial organisation that is at risk of being exposed to bribery needs an anti-bribery policy to comply with legislation.
The Bribery Act 2010 creates offences of offering or receiving bribes and failing to prevent persons associated with your organisation from committing bribes on its behalf.
An anti-bribery policy is necessary to comply with the law and ensure that your organisation proportionately counters bribery and corruption.
What is classed as bribery?
Bribery is an unethical gesture intended to influence a person’s behaviour by offering a financial or other advantages.
Bribes are often business-motivated and come in many forms, but they always intend to achieve an advantage, whether it be financial or preferential treatment.
Unfortunately, bribes can be difficult to spot. Is offering a referral fee to an executive in another company to win a contract a bribe? Is offering a female employee a bonus in return for coming back to work early from maternity leave a bribe?
Because bribes can be difficult to spot, anti-bribery training is essential for commercial organisations. By knowing what a bribe looks like, everyone in your organisation will be able to avoid it, spot it and stop it before it escalates.
How can you reduce bribery in your organisation?
The most important thing is to understand the legislation surrounding bribery and create an anti-bribery policy around that legislation.
One of the most important aspects of your policy will be anti-bribery training so that everyone in your organisation can recognise bribery and react to bribery attempts correctly.
Like all procedures, training should be proportionate to risk, but some training will also help to establish an anti-bribery culture in your organisation.
We recommend mandatory general training for all employees that covers education and awareness raising about bribery. More intensive training may also be needed for people in higher-risk roles such as finance, purchasing and IT.
Our anti-bribery course is a great place to start. It’s accredited by the National Cyber Security Centre and simplifies the intricacies of bribery legislation, with engaging animations and simple, effective language.