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What are Adequate Procedures ? ACFE March 1st 2011 Robert Barrington Director of External Affairs, Transparency International UK. Key features of the UK Bribery Act. Result of external pressure on UK government ‘ By no means stricter than …other OECD member states’ Extra-territorial

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What are Adequate Procedures?

ACFE

March 1st 2011

Robert Barrington

Director of External Affairs, Transparency International UK


Key features of the uk bribery act
Key features of the UK Bribery Act

  • Result of external pressure on UK government

  • ‘By no means stricter than …other OECD member states’

  • Extra-territorial

  • Corporate liability


Adequate procedures
Adequate Procedures

  • A legal defence for ‘failure to prevent bribery’ [Bribery Act, section 7]

  • Outlined in UK Government Guidance

  • Not a defence for a company that has knowingly paid a bribe



1 the six principles transparency international s view
1. The Six PrinciplesTransparency International’s view


Six principles
Six Principles

  • Tone from the Top

  • Risk assessment

  • Detailed Policies & Procedures

  • Implementation

  • Due diligence

  • Monitoring & Review




Corruption perceptions index1
Corruption Perceptions Index

  • Ranks countries 1-180

  • Scores countries 0-10

  • Measures perceptions of public sector corruption

  • 133 countries score less than 5 out of 10

  • 2010 best performers: NZ, Denmark, Singapore, Finland, Sweden

  • 2010 worst performers: Somalia, Myanmar, Afghanistan

  • Undertaken annually


Bribe Payers Index 2008

Country’s companies least likely to pay bribes

  • 22 countries ranked representing 75% of global exports of goods and services and outflows of foreign direct investment in 2006.

  • Based on responses of 2,742 senior business executives from companies in 26 developed and developing countries, chosen by the volume of imports and inflows of foreign direct investment.

  • Conducted every two years

Country’s companies most likely to pay bribes


Bribe payers index high risk sectors
Bribe Payers Index: high-risk sectors

Bribery of Public Officials by Sectors 2008

  • Worst performers

    • Public works contracts & construction 5.2

    • Real estate & property development 5.7

    • Oil & gas 5.9

    • Heavy manufacturing 6.0

    • Mining 6.0

  • Best performers

    • Banking & finance 7.1

    • Fisheries 7.1

      likelihood of companies in each sector to bribe public officials [possible scores range from 0 to 10. 0 represents the view that ‘bribes are almost always paid’ and 10 that ‘bribes are never paid’ by a sector] – extract below of best and worst performers. Source? TI Bribe Payers Index 2008


Global corruption barometer
Global Corruption Barometer

  • Citizen’s view of corruption in their own countries

  • Opinion survey of 77,000 citizens conducted in c.75 countries

  • Every two years


Where are bribes paid source global corruption barometer 2010
Where are bribes paid? [source: Global Corruption Barometer 2010]


Perceptions and reality: CPI vs GCB?[source: Corruption Perceptions Index & Global Corruption Barometer 2010]


Other risk areas
Other risk areas

  • Country risk

  • Sectoral risk

  • Transaction risk – eg licences, permits, procurement

  • Opportunity risk – eg high-value contracts

  • Partnership risk – eg joint ventures, local agents



Business principles for countering bribery
Business Principles for Countering Bribery

  • High-level principles

  • Developed by TI

  • Multi-stakeholder process

  • Similar to PACI and ICC




20 point abc checklist
20-point ABC checklist

  • Board member’s airport checklist

  • Global comparison score in your sector [Materials]:

    • number of companies reviewed: 46

    • highest score: 45 points; 5 stars

    • lowest score: 0 points; 0 stars

    • median average score: 18



Conclusions
Conclusions

  • Don’t pay bribes

  • Tone from the top

    • corporate culture

    • zero tolerance approach

  • Fully analyse and understand the risks

  • Put in place a robust anti-corruption system

  • Don’t rely solely on the government guidance

  • Don’t pay bribes


Documents and links available at:

www.transparency.org

www.transparency.org.uk

www.adequateprocedures.org.uk


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