FOCUS ON PLANNING
So, before we introduce a anti-corruption strategy, we should plan to ensure that we have or are able to build an anti-fraud and corruption culture. We must first be clear about the result we want to achieve. If an organisation lists staff integrity and ethics as its values, do we really ‘walk the walk’ and ‘talk the talk’ or simply provide empty rhetoric which, in our experience, demotivates staff who may feel patronised by senior management? Once we know where we are then we can start designing a roadmap.
COMMUNICATING ANTI-FRAUD INTENT
To understand where current culture is it is important to engage staff that includes within the solicitation and full consideration of their views in what needs to be done to make the change. We often hear about the ‘tone at the top’ but we rarely consider the ‘mood in the middle’ or the ‘reality at the bottom’. Only with this engagement do we have a greater chance of success because the staff on the ground know from practical experience how the reality of business operations can undermine many of the principles the organisation stipulates that it abides by.
Thus, for example, the organisation may have a strict policy on refusing all gifts tendered by a supplier in pursuance of a contract, but it might be asking a great deal of a sales executive in a far flung jurisdiction to potentially scupper a deal by ‘offending’ that supplier and refusing to take the gift. This is the type of pinch point which demonstrates the true value of any anti-fraud and corruption culture – could the sales executive in reality refuse the gift, scupper the deal and walk back into his organisation and receive a pat on the back from his managers? If the answer is no, then the anti-fraud and corruption policy may not be as robust as management perceive it to be.
How do we communicate our culture and stance to our partners and suppliers? Having the correct message may have the impact of reducing external fraud and bribery attempts because fraudsters realise that there is a greater chance that they will get caught.
Introducing an anti-fraud and corruption culture is only one part of an anti- fraud strategy but is an important component in achieving success in profiling risk and introducing risk mitigation. If we want our staff, partners or suppliers to report fraud and corruption and assist us in risk mitigation, to allow our organisation to profile the fraud risks that directly affect the organisation and its response, to introduce an anti-fraud culture we need to define what we are doing right and communicate what needs to be done in order to build a successful approach.