CIPFA examines the ‘red flags’ in behaviour that will help individuals notice if they're running foul of the UK Bribery Act 2010.
Bribery is not always obvious, and sometimes it’s cloaked in goodwill. It’s these subtle variations of approach and behaviour, which often cause individuals and organisations to fall foul of the UK Bribery Act 2010.
Frequently the issue is not the bribe itself, rather the back-story, context, form and language in which it is dressed. This is especially the case in situations where it is neither clear nor obvious what the risk or threat is.
Identifying and being aware of ‘red flags’ in behaviour will help individuals to notice whether what is being suggested is a bribe or not. So, when dealing with clients, developers, customers or contractors, what can you do to avoid being exposed to a potential bribe?
In essence, it’s about being professional and taking care, which means DON’T:
- Agree to meet alone
- Allow over-familiarity
- Give out your personal mobile number
- Meet informally outside working hours and away from your organisation’s premises (and certainly don’t do so without getting formal approval)
- Allow too frequent contact or over familiarity that may be acceptable with friends, colleagues and family but not from people with whom you only have a commercial relationship
- Discuss your private life, or social or recreational interests of you or your partner
- Accept offers, discounts or other services or products by the client, customer or contractor
- Accept hospitality, gifts etc., you yourself wouldn’t pay for from your own pocket
- Do anything that makes you feel uncomfortable, obligated or might be open to misinterpretation or might be difficult to explain to your manager, a journalist or an investigator.
It’s also essential that your organisation has the necessary policies and procedures in place, plus a well-publicised and confidential means for getting advice or for reporting unwelcome approaches or suggestions. These will act as a system of checks and balances to help prevent bribery and misunderstanding.
Boosting your bribery defences
As part of our commitment to the UK Government’s Anti-Corruption Plan, the CIPFA Counter Fraud Centre offers an Anti-bribery and Corruption e-Learning Package to equip organisations with the skills and knowledge required to effectively block and prevent bribery in the workplace.
The e-Learning Package is geared towards those on the ground who have increased exposure to bribery risk. Many people in the UK, and UK citizens working abroad for public, private and not-for-profit organisations, need to be alert to risks and to the development of a relationship that could lead to a bribe being hinted at, offered or even accepted. The Package makes navigating the murky waters of bribery easier as it brings clarity to what is often perceived as a complex area of regulation.
The e-Learning Package includes an in-depth e-learning course on the Act, covering key definitions, main offences, jurisdiction, as well as advice on how a public body involved in commercial activity can defend itself against criminal liability under the Act.
It also includes a short, interactive slide-set designed to be shared across the organisation. It features engaging graphics and illustrations to illustrate how to recognise a bribe and what action can be taken in response.
Training is also available for those responsible for managing their organisation’s bribery and corruption risks and ensuring compliance with the requirements of the UK Bribery Act 2010.
The Centre has worked with the City of London Police’s Economic Crime Academy to develop the Certificate in Anti-Bribery and Corruption Studies. Bribery is an economic crime that is distinct from fraud and which retains its own distinguishing characteristics and features.
Employers need assurance that those who are managing their bribery and corruption risks know their subject and are equipped with the necessary knowledge and skills to effectively perform their role. This professional, accredited qualification provides this assurance, delivering in-depth knowledge, understanding and skills.
For more information about the e-Learning Package and the Certificate, use the links below or contact the Centre on 0207 543 5600.
To learn more about the Anti-bribery and Corruption e-Learning Package, click here
To learn more about the Certificate in Anti-Bribery and Corruption Studies, click here