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Anti-bribery and corruption during COVID-19: Six tips for compliance officers

Written by Sophie Ogilvy on Thursday, 9 April 2020

COVID-19 has disrupted everything – supply chains, the market, how we work and how we interact with each other. For compliance teams, flexibility and adaptation are key to ensuring that you are on hand for your business to guarantee that it is making the best possible decisions when under pressure.

The Business Integrity team at Transparency International UK has compiled some top tips to ensure that you can keep your organisation running with integrity during this global crisis and ensuring anti-bribery and corruption (ABAC) best practice.


1. Ensure you have a good risk-assessment framework and that you are actively using it as your business changes.

This is particularly important for organisations whose business models have changed dramatically, such as those who have pivoted to support efforts to produce healthcare products or whose supply chains have shifted dramatically from one region to another. New geographies and new sectors bring new bribery and corruption risks and in many cases, additional regulations. These must be assessed, understood and mitigated – even in these challenging times and even by those businesses who genuinely want to support the effort to combat COVID-19.

Transparency International UK’s Diagnosing Bribery Risk is a detailed guide for business on how to conduct a risk assessment and how to use it effectively to protect your business and reduce risks of corruption. Our Global Anti-Bribery Guidance Portal (more on this in tip 4), has also recently undergone a major revamp to ensure it continues to offer up-to-date summaries of anti-bribery legislation. This includes information from jurisdictions across the globe, including China, Brazil and Ukraine, to help businesses as they navigate new markets and their differing legislative landscapes.

2. Tone from the top has never been more important.

Make sure that your C-Suite are living and breathing integrity. Now more than ever, it is critical that business leaders act with integrity and ensure that their employees are doing the same. They can do this through regular communication with employees – perhaps a short video reminding staff of the company’s values and ethics priorities.

If you are worried that your Senior Management team are not taking this seriously, we hope our recent Open Business report will help. It sets out the business case as to why conducting business ethically and reporting openly, particularly about ABAC issues, is critical to building trust with customers, investors, your employees and the general public. All eyes are on businesses right now – and reputations are at stake.

If you have people in your teams or in the wider organisation who have less to do in these turbulent times, a useful exercise might be to review what the business is disclosing against the principles set out in the report. The question we are challenging businesses to address is ‘why not disclose?’.

3. Review your lobbying practices to ensure you have ethical policies and procedures in place and ensure you are open about what you are lobbying for/against.

Most, if not all, businesses lobby government and this is a perfectly legitimate business activity – when done responsibly. At this time of crisis, where government policy is being created and implemented at pace and where markets and sectors are facing huge amounts of disruption, we have already seen in many markets a huge upsurge in lobbying activity. At this time where lives and livelihoods are dependent on the decisions made, it is all the more critical that businesses do not exert undue influence over political decision-making. You can evaluate your lobbying practice against our best practice using our 2018 Corporate Political Engagement Index.

4. Consider conducting a self-assessment of your Compliance programme to ensure it is fit-for-purpose.

Budgets are tight across many businesses right now, meaning external monitoring and review of programmes may be difficult to sign off. Many internal investigations and audits will be put on hold too. Whilst this is not ideal, it presents an opportunity for your team to review the policies and procedures that you do have in place and see whether your Compliance programme does have ‘adequate procedures’. Transparency International UK offers a free-to-use Global Anti-Bribery Guidance Portal. The Portal includes practical summaries of anti-bribery legislation from jurisdictions around the globe and provides an 18-module set of guidance covering topics including risk assessment, due diligence, managing third parties and aligning incentives to behaviour.

For those who still have a modest budget, we also offer our Corporate Anti-Corruption Benchmark that allows you to assess your company’s ABAC programmes against global legal requirements and against our best practice – ensuring your company stays ahead of the game and is able to effectively demonstrate adequate procedures. Not only that, but by participating, you are supporting our mission to fight corruption. The 2020 Benchmark is launching on the 6th April this year and is still open for new participants.

5. With many of your sales colleagues unable to travel, seize this opportunity to conduct training on ethics and compliance.

When the COVID-19 crisis is over, your sales and frontline colleagues will be back out there in the market. Scheduling training – even short refreshers – is a good way to demonstrate your company’s commitment to ethics at this time. Even if you don’t have training materials ready, we have some free-to-use online training which you can use. It is also customisable for a small cost. If you feel that you really want to seize this opportunity, we are still offering virtual face-to-face training to support businesses.

6. Reiterate your ethical requirements – such as your code of conduct – to your suppliers at this time and keep track of how your suppliers’ risks profiles may be changing.

All businesses are under pressure at the moment, whether they are positively or negatively impacted by COVID-19. Your suppliers and wider supply chain will also be feeling these effects and will be making some difficult decision. You need to ensure that you manage those risks effectively too. Third party management is always a high-risk area for business, but now more than ever. We have a whole section of the Anti-Bribery Guidance Portal on managing suppliers and contractors. Key things to consider are regular communication with your suppliers about changing risks, conducting renewed due diligence and setting expectations of exercising audit rights when possible again.


The Business Integrity team at Transparency International UK have spent decades curating expert evidence-based advice and knowledge to create a range of anti-corruption and bribery best practice resources to support your ABAC programmes. We have highlighted some of these resources in the tips above, and are continuing to conduct research and compile best practice guidance for businesses during these disrupted periods.

We are always looking to understand more about the pressures companies are facing, particularly at this unique time, so that we can conduct research and consolidate best practice to share with the wider community.

We are also committed to convening expertise and offering guidance to businesses with the tools they need to combat corruption at this critical time, so watch out for upcoming webinars in which we convene compliance teams from multinationals to talk about how they have reacted and adapted to global changes since the start of the COVID-19 pandemic.

If you would like to contact us to share your experiences, or to learn how we work with companies, email us on businessintegrity@transparency.org.uk


Read 877 times Last modified on Thursday, 09 April 2020 12:18

Sophie Ogilvy

Sophie Ogilvy is the Programme Director at Transparency International UK which works with companies to raise anti-corruption and business integrity standards in the private sector.

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