The 2019 Survey on Anti-Bribery & Corruption was conducted jointly by Compliance Week and Refinitiv over the course of two months in early 2019, generating 233 total responses from anonymous compliance and risk professionals and revealing some surprising (and a few alarming) trends.
The survey was comprised of 20 questions and was broken up into three parts: a basic benchmarking of a respondent’s anti-bribery, anti-corruption program; a look at how companies evaluate and monitor third parties (including a deeper dive on enhanced due diligence); and an evaluation of training programs with a particular focus on automation and advanced technologies.
What follows are key takeaways from each section:
- About two-thirds of those surveyed rated the effectiveness of their anti-bribery program either a 4 or 5 (on a scale of 1-5, with 5 being most effective), with just 12 percent giving themselves a 1 or 2.
- Overall, 67 percent of respondents indicated they had adequate resources to ensure the success of their anti-bribery program.
- Nearly 80 percent of respondents expect their bribery and corruption risks will either increase or remain the same over the next 2-3 years.
- What types of misconduct do compliance officers define as corruption? Of the eight options, the most common selections (respondents could choose all that applied) were bribery, fraud, money laundering, price fixing, and bid rigging, all garnering the votes of more than 50 percent of practitioners who took the survey.
- Perhaps the most encouraging result: 87 percent of respondents say their companies have programs in place that encourage whistleblowers and thwart retaliation.
Third parties and “enhanced due diligence”
- The most concerning result was that 38 percent of those polled indicated they never train their third parties on anti-bribery and corruption. Among that group, 28 percent indicated they expected their ABC risk to increase over the next 2-3 years and a whopping 43 percent said they have third parties operating in high-risk or sanctioned jurisdictions internationally. (Overall, just over 50 percent of respondents said they have partners doing business in high-risk areas.)
- Almost everyone whose job it is to ensure quality training for third parties will tell you that nothing can replace boots-on-the-ground, in-person training, even for international entities. Just 30 percent of those polled, however, conduct on-site anti-bribery/anti-corruption training for their third parties. Among companies that indicated they have third parties that operate in high-risk areas internationally, that number creeps up to 33 percent.
- The most likely reason a third party will fail to meet an organization’s standards is “general reputational or integrity concerns” (selected by 56 percent of respondents), followed by “unusual contract and payment structures” (36 percent), “suspect corporate structures” (28 percent), and “questionable relationships with politically exposed persons” (27 percent).
- The biggest factor in a company’s decision on whether “enhanced due diligence” is needed for a third party is geographical risk, according to the survey, followed by past behavior and industry-related risk.
- Overall, 54 percent of those polled said less than a quarter of their third parties undergo “enhanced due diligence”—by far the most popular answer. About 13 percent indicated that none of their third parties undergo that level of extra scrutiny.
- The added cost of enhanced due diligence is the biggest challenge for companies, according to the poll, followed closely by a “lack of knowledge.”
Effectiveness and automation
- Companies seem to be better at training domestic employees on rules and procedures than they are at doing the same for their international workers. About 62 percent of those polled gave themselves the equivalent of an A or B when asked to evaluate how effective they were at training U.S.-based workers. Internationally, less than 50 percent of respondents gave their companies those same grades.
- It seems most companies polled have automated processes in place to carry at least some of the load for their anti-bribery programs. Those polled were offered five answers to a question about which parts of their programs were automated, and each of the five got a check in the box from at least 30 percent of respondents. Training domestic employees (51 percent) and monitoring and certifying third parties (43 percent) were the leading vote-getters.
- While the rate of adoption for automation was high, the same cannot be said for emerging technologies. We asked whether companies were using or planning to use artificial intelligence, blockchain, or machine learning to enhance their anti-bribery programs, and a surprisingly high 67 percent answered “none of the above.” AI was next at just 21 percent.
Anti-bribery and anti-corruption survey
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