"Businesses should not directly or indirectly offer, promise, give or solicit bribes or other improper advantages to obtain or retain a contract or other improper advantage."
The OECD describes in its Guiding principle
on the fight against corruptionin supposedly understandable terms, which every company should
every company should adhere to. The fact that this looks different in practice
and does not always comply with the guiding principles, is unfortunately a fact,
that we have also had to experience in our company.
In very few cases will those affected have thought in advance
thought about the risks involved in paying or receiving bribes.
bribes entails. This makes it all the more important for a
to speak out against it in principle and to establish clear guidelines.
Alarm bells at the South African site
In this case, there was a possible case of corruption in the subsidiary of a stock exchange group listed in the USA. The company, which is based in the oil and gas industry, is alleged to have paid bribes in South Africa, where the subsidiary is based, in order to obtain public contracts.
At first, they are 'only' accusations that need to be investigated. The next moment, however, it becomes clear what risks are suddenly in the room:
- Black-listing of the Group in the USA for public contracts. If this condition were to occur, approx. 50 % of Group sales cease to exist, as this revenue is based on business with the U.S. government.
- Prison sentences for the responsible managers.
- High Penalties in the double-digit millions.
In order to contain the crisis situation and, above all, to eliminate the risks, Jan-Hendrik Heinen is called in as Manager Internal Audit. His tasks focus on recording a complete and proper picture of the situation, analyzing the current situation and drawing up suitable corrective measures.
Internal audit should bring clarity
As the responsible project manager, he takes over the planning of an internal audit. The focus of the audit is on the procurement and evaluation of collected information. Specifically, this includes the following steps:
Measures operational:
- Management and implementation of a "surprise audit" on site
- Conducting forensic examinations and analyses
- Conducting interviews with stakeholders
Measures organizational:
- Assembling a team of specialists
- Compilation of a focused audit program as well as a corresponding so-called documentation request
- Stakeholder involvement at Group level
Measures communication:
- Ensuring the necessary secrecy and corresponding instruction measures
The internal audit revealed that the team needs to be retrained in some areas. Appropriate measures are being implemented so that all employees have the same level of (knowledge) and potential risks due to ignorance are contained in the future.
In addition, a company-wide anti-corruption policy is being developed, which will subsequently be integrated into the corporate structure. Employees are trained and sensitized to the issue. The knowledge gained can thus be transferred to future scenarios.
