With the changing global climate, a rising trend of remote working, and an increase in the occurrence of technological threats, compliance practitioners must be more vigilant than ever before. The need for a strong framework for training, monitoring, and due diligence has become quintessential, considering the current business environment and sensitivity of corporate information.
There have been major government interventions across the globe, following the COVID-19 outbreak. With rapid policy changes, ranging from revised guidelines to new standard operating procedures and the disbursal of stimulus packages to revive economies, the threat of misuse of funds has never been this significant.
These changes present substantial challenges in the form of governance and compliance during the transition period and the short-term. Anticipating such challenges, Nexdigm (SKP) reached out to leading anti-corruption practitioners in an attempt to understand the anti-bribery and corruption scenario in their region, that culminated in a series of podcasts called 'Global Anti-Bribery and Corruption Insights' with experts from 15 geographies across the globe.
Nexdigm's webinar on Global Anti-Bribery and Corruption, conducted on 8 September 2020, discussed the key factors, critical risks, and imminent steps to create proactive due diligence for companies to stay abreast of the latest threats arising from employees working remotely. The expert panel at the webinar included Amii Barnard (C-Suite Coach, Consultant, and Corporate Governance Expert), Thomas Fox (Principal, The Compliance Podcast Network), Sundar Narayanan (Director - Forensics, Nexdigm), and Mayank Lakhani (Senior Managing Director - Assurance, Nexdigm).
The panel highlighted key issues pertaining to compliance officials, including channels of training, innovating suggestions for training modules, effective channels of communication, effective communication strategies for the current scenario, the importance of due diligence for developing economies, internal monitoring controls, and several other crucial considerations to mitigate bribery and corruption.
Speaking on the principles to keep in mind while conducting compliance training, Amii Barnard said, "There are three main points to keep in mind. Be relevant, be culturally literate, and recognize adult learning principles. You have to keep in mind the background of the people with whom you are speaking. It is very important that they understand you clearly and resonate with what you say. Creating a story also helps when teaching adults because they are naturally more inclined to understand information through storytelling. Also, ensure you are creating a two-way form of communication. Gaining feedback on programs is as essential as providing information because then you can start a cycle of continuous improvement".
Thomas Fox, the author of the award-winning FCPA Compliance and Ethics Blog and the international best-selling book 'Lessons Learned on Compliance and Ethics', strongly agreed with the burgeoning requirement for compliance training and emphasized the need of focused training for high-risk employees. Thomas also noted the importance of having an internal ethics champion. He stated, "Don't just plan it, do it. Having an ethics champion accessible to employees is invaluable. Trained ethics champions available at the front-line can help employees with ethical decisions and provide information back to the compliance department. This will create a constant feedback loop that will elevate the overall work culture. Employees can approach the champion to solve their problem, making it a very powerful tool. Compliance champions will be the on-ground eyes and ears of the compliance committee."
Sundar Narayanan, head of Forensics at Nexdigm, was most concerned with the state of control monitoring, which has an impact on nearly every process of an organization, from due diligence to sales. Speaking on the seven factors for control monitoring, Sundar noted, "Control monitoring starts with a management commitment which could span regional or functional management, as the case may be. The second step is 'clarity and communication', which includes assessing how the policy is communicated and how clear the policy and expectations are. The third key factor is 'risk acceptance and incentivization', which involves assessing and accepting risks, and preparing mitigation plans while conducting businesses that are usually incentivized. The next is 'expectation and measurement', which broadly covers creating a set of expectations and monitoring those expectations at a process level."
"The fifth, sixth, and seventh critical factors are stakeholder engagement, budget and resources, and governance, reporting, and action. Stakeholder engagement is very critical; compliance managers must be deeply engaged with stakeholders. The budgets and resources of the compliance team must also be checked to understand whether they have adequate means to effectively manage the overall controls. The final step is 'governance, reporting, and action', which refers to all these factors being monitored, evaluated, and recalibrated to ensure continuous improvement." said Sundar, who believes metrics play a key role in reflecting expectations.
Nexdigm also launched a report on 'Global Anti-Bribery and Corruption Insights', which captures important excerpts from the podcast series. It shares perspectives on the current risks, compliance enforcement trends, suggestions for compliance officers, as well as training and communication programs that can be incorporated to mitigate these risks in different geographies.
The report covers crucial factors, including corruption risks amidst the current pandemic, the impact on government touchpoints, anti-corruption enforcement trends, and suggestions for compliance officers across 15 countries. To read the complete report, please click here.
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