Managing safety, corruption and business integrity risk:Protecting your business from bribery and corruption

What is corruption and bribery?

The government defines corruption as the abuse of entrusted power for private benefit that usually breaches laws, regulations, standards of integrity or standards of professional behaviour.

This can include:

• abuse of the power given to an individual by another person or organisation
• activity that’s beyond the position or remit of a person
• benefits taken for an employee’s personal gain, rather than for their organisation

Bribery is defined as the offering, promising, or giving of something to influence an official, including:

• payments to get a faster or better service or to gain advantage in public procurement processes
• offering, providing or receiving gifts, entertainment, and hospitality – or other items of value such as donations, sponsorships and internships
• levels of hospitality disproportionate to a business transaction

Your company’s exposure to these may vary from one country to another. But you should always keep your eyes open for the warning signs.

How to spot corrupt behaviour

Corrupt behaviour is often hard to spot, especially when you’re operating in an unfamiliar culture.

When doing business, pay close attention if the people you're dealing with:

• try to rush through any business without allowing for due diligence
• provide very little paperwork
• insist on using specific suppliers without making a business case
• request unusually high, or low, fees or commission for your chosen market
• have been found guilty of misconduct due to the nature of their relationship to a government official, or other influential person
• refuse to have a written agreement or sign a contract
• request payments are made into an offshore account, in cash, or to a charitable cause

What to do if you suspect corruption

If a deal looks too good to be true, or a payment seems suspicious, ask yourself a few questions:

• does this seem appropriate, relevant and proportional?
• does it feel right, does it make sense?
• would you proceed if this were happening back in the UK?

If the answer is no, seek guidance from local embassy representatives, the UK trade team or your own legal team.

Due diligence doesn’t just mean pages of detailed documentation. It can also mean simply asking the right questions at the right time, keeping your eyes open to things that feel irregular, and getting the right advice if something doesn’t feel quite right.

Doing nothing can lead to serious consequences further down the line.

How to avoid corrupt behaviour

Before you do business with another organisation, it’s important to carry out background checks. When looking at potential partners, pay close attention to:

• ownership, structure and financing
• industry standing and reputation
• qualifications and accreditations
• compatibility with your organisation’s culture and ethics
• customer references and case studies
• third party references, for example banks, accountants, industry bodies
• presence and standard of locations and physical infrastructure, for example offices and warehouses

Use trusted organisations to help you perform checks, including international trade advisers, local embassies, etc, and refer to government blacklists and third-party sanctions databases.

The Organisation for Economic Co-operation and Development (OECD) due diligence guidance for responsible business conduct gives practical advice for international traders.