Taking a first step in providing anti-fraud and corruption training and raising awareness or undertaking an organisation risk review are positive steps forward in mitigating these risks. However, if there is no long-term plan to develop an anti-fraud culture that includes buy in from and consistent leadership from the CEO and senior management of an organisation, then any attempt at culture change is likely doomed to fail.
Culture is the widening of the mind and spirit
Defining organisational goals, mission, vision and values, publishing policies and procedures that align with each other is one thing and using such phrases as ‘walking the walk’, ‘talking the talk’, ‘practicing what we preach’ and ‘leading by example’ is another, but if we don’t have real and demonstrative leadership and ownership in terms of an anti-corruption culture then how can we expect compliance and support from the rest of the organisation when we seek to create and disseminate such cultural change?
There are a number of key factors that are incongruent with building an anti-fraud culture that would need to be addressed before an organisation was able to introduce a successful fraud and corruption risk mitigation framework.
- Is anti-corruption communicated from the top, is it a priority for the CEO and board and are their actions documented and visible to the organisation?
- Is there an anti-corruption owner, definitive action taken where corruption is identified? Is the culture consistently part of the discussion and issues raised acted upon or is it just empty words? We have seen too many organisations globally that have an anti-bribery message and policy but have still been prosecuted for their actions or inaction to prevent it or have punished whistleblowers for their disclosures.
- Are values and behaviours published and practiced, are we clear on values or are there acknowledged and accepted grey areas such as conflicts of interest, gifts and hospitality and the lack of declaration, reporting or response where non-compliance is known? Do the published values and behaviours form part of our performance review?
- How can we inspire staff to protect the organisation’s revenues when typically, their views aren’t sought on culture, risk identification and mitigation both at the crucial stage of setting out organisational policy and during day to day operations of the organisation?
- How do we ensure that we communicate to the whole organisation and if we don’t seek their views and professional expertise how can we reasonably expect culture to change?
- How do we introduce regular and honest communication that is rapidly, demonstrably and effectively responded to?
- How can staff report corruption and fraud when there is no, or limited, awareness or training? What do current typologies look like and what controls are available to reduce the risk?
- Why would staff report fraud if they aren’t protected from reprisals because of a lack of confidential and objective internal reporting routes and/or a whistleblowing protection framework?
- Is there accountability and are staff that breach organisation codes of conduct or anti-fraud policies dealt with correctly? Many organisations may, for example, seek merely to remove the identified fraudster without establishing the flaws in systems or processes which facilitated his or her activities and thus leave the way open for subsequent fraudulent activity.
- How do we communicate to staff, partners and suppliers that we take bribery and corruption seriously and act?
- Do we measure our anti-fraud culture performance, does it translate into an increase in risk identification, reporting and mitigation?
- Do we look for continuous improvement, measuring success and impact of the anti-fraud culture and where flaws are identified ensuring that those are rectified immediately? Equally, it is important that any document enshrining the culture does not become dormant but evolves as the situations the organisation finds itself in do.
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.
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