Companies Improve Response to Unethical Conduct

Companies are taking a firmer stance on responding to unethical conduct, with more than three in four reporting instances of bribery when they become aware of it according to Dow Jones’s 2015
State of Anti-Corruption Compliance Survey

Dow Jones Risk & Compliance surveyed nearly 290 compliance professionals globally to better understand their top challenges and concerns in dealing with anti-corruption compliance.

The results indicate that the number of companies monitoring business partners at least quarterly has nearly doubled in the past year, while more than 10% of all survey respondents now monitor partners daily; an annual increase of nearly 60%.

The survey also showed that corruption concerns are increasingly impacting companies’ decisions about forming or expanding partner relationships and conducting business in emerging markets, mirroring an ongoing trend over the past three years.

Of the companies represented, more than two thirds stopped or delayed working with a business partner due to concerns about violating anti-corruption regulations. More than 50% of respondents said they had stopped or delayed a venture into emerging markets (EMs) for the same reason.

Less than a third of compliance professionals surveyed reported having lost business to unethical competitors; a steady decrease from previous years. Among companies losing business, nearly 70% cite non-compliant competitors and more than 70% mention losses to companies not required to comply with anti-bribery regulations; a significant increase on past years.

“It’s clear from this year’s survey that global corporations are being more proactive in their monitoring and disclosure of unethical behaviour within their organisations,” said Joel Lange, managing director, risk and compliance, Dow Jones & Company.

“While most corporations now have well established anti-corruption programs, the focus appears to be on getting the right controls in place and ensuring monitoring is being done more frequently to ensure regulatory compliance”.

In general, the incidence of anti-corruption programmes has remained mostly steady for the past four years (currently at 90%), with more than half the companies having had programmes in place for more than six years. Half of the companies without programmes believe other policies already cover anti-corruption issues adequately.

As in previous years, most (95%) anti-corruption programmes include internal codes of conduct and internal training. All other anti-corruption programmes bettered their 2014 levels, including risk ranking of partners and business partner training.

The survey also showed that companies still struggle with due diligence, despite its growing importance, but an increasing number feel confident about their programmes. The proportion of companies updating their due diligence at least every two years has increased 35% over the past year, while an increasing number say that sales agents, senior executives, board members and suppliers should be subject to due diligence.

The issue of facilitation payments continues to divide respondents. Although nearly 30% feel it’s realistic to ban them, an increasing number of respondents aren’t sure it’s possible, citing such reasons as reliance on payments by government officials, differing cultural expectations and the requirement to participate in payments in order to do business in some countries.


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