Assessing bribery and corruption risks
These questions can help you assess whether your business may be at risk of breaching bribery and corruption laws in New Zealand and overseas.
- Is there a strong message of 'zero tolerance to corruption' from those at the top of the organisation (directors and senior management)?
- Is the organisation operating in any high risk jurisdictions (refer to Transparency International's Bribery Payers and Corruption Perceptions Index) or high risk sectors (e.g. defence, oil and gas, property development, shipping)?
- Do you have a comprehensive code of conduct which must be signed by staff and agents in all countries where the organisation is operating?
- Are system processes and internal controls in place to support the code of conduct (in particular: clear procedures on gifting/corporate hospitality/entertainment, staff training and whistle-blower protection)?
- Do you have a dedicated position (such as a compliance officer) with overall responsibility for the organisation's anti-corruption programme across all countries?
- Are staff actually implementing the organisation's anti-corruption policies?
- Are employees circumventing established organisational processes or arguing special cases?
- Do employees have an unusual interest in a particular contract or a specific contractor?
- Is an employee's lifestyle at odds with their known level of income?
- Are you fully aware of activities of your overseas agents (for example, no indication of 'splashing the cash' to attract business)?
For a more detailed list of warning signs of bribery and corruption, see What to watch for.