Understanding pandemic-related challenges for bribery compliance

Hybrid working is here to stay. In between Covid-19 waves and rushes to and from the office, even as people return and restrictions are lifted, hybrid working is likely to be with us going forward. This has caused significant challenges for compliance, but businesses have adapted with online solutions. From due diligence checks to virtual happy hours, much of the in-person activity which takes place in an office has been replicated online.

But compliance challenges remain, particularly in the realm of bribery compliance, and gifts and hospitality. It was one of the first things to take a hit in the pandemic. If no one can go out, then there’s no risk in a supplier-paid meal infringing on bribery rules. With foreign travel more difficult and subject to greater restrictions, it is harder to bribe someone with an all expenses paid trip abroad.

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Bribery can have serious legal and reputational consequences for your organisation and, in some countries, organisations can even be prosecuted for failing to prevent employees from committing offences. But demonstrating that there were adequate procedures in place to prevent bribery could be crucial to a defence in ‘failure to prevent’ proceedings. A gift and hospitality (G&H) register is one such procedure. A comprehensive gifts and hospitality register can also help organisations keep their accounting records up to date.

To help your organisation get up to speed, VinciWorks has created a guide on best practice guidance for gift and hospitality registers. The guide features an introduction to gift and hospitality registers, which answers questions such as what they are and who needs them, and offers six tips for implementing a G&H register.


Click here for a free download of the guide.

Navigating international laws and regulations around bribery can be very complex. Cultural customs can sometimes amount to bribery. What may be regarded as perfectly ‘normal’ and acceptable practice in a country can still be considered a bribe, even when a reward or ‘tip’ is expected, and even if everyone does it.

Global guide to anti-bribery laws

To help in the quest for compliance, VinciWorks has created a country guide to bribery. The guide includes guidance for over 70 countries. For each country, there is a summary of key bribery offences, who it covers, if businesses are required to have procedures in place, hospitality rules, facilitation payments and legal penalties.

We recommend using this guide in risk assessments and country-specific policy development. Risk assessment forms a key part of any anti-bribery and corruption programme and once risks are identified, such as business operations in high-risk jurisdictions, additional measures can be implemented which may, in some jurisdictions, form the basis for a legal defence if any employees or agents engage in bribery.

Download the guide

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A big pile of gifts

Does your organisation have an up-to-date gifts and corporate hospitality policy in place? Are you able to easily register any gifts you receive or give? Having an up-to-date gifts and corporate hospitality policy in place will help you comply with your responsibilities under the Bribery Act and other anti-corruption legislation.

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What should be included in a gifts and corporate hospitality policy?

The purpose of such a policy is to ensure that your organisation and its employees comply with the anti-bribery and corruption policy, bribery laws and best practice in combating corruption in all of the countries and business areas in which you operate. The policy should complement your organisation’s bribery and corruption policy. Here is some guidance on what the policy should include.

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Man in handcuffs holding money

In 2020, Airbus paid a record £3bn in fines for ‘endemic’ corruption. This settlement surpassed the previous UK record for a corporate fine for bribery, which was the £671m paid by Rolls-Royce, Britain’s luxury car manufacturer, in 2017. 

Despite the UK Bribery Act having come into force in 2010, bribery is still a hugely problematic issue in corporate life. Billions of pounds of fines are levied every year and frequent reports hit the headlines of investigations and prosecutions from the US Department of Justice and UK Serious Fraud Office.

Companies should have strict policies in place to ensure all employees understand the steps they need to take to ensure their company cannot be found liable of bribery or corruption. The policy should apply strictly to all employees, partners, agents, consultants, contractors and any other people or bodies associated with the organisation. VinciWorks has therefore created an anti-bribery and corruption policy that can easily be edited to suite your organisation’s staff and industry.
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Despite the UK Bribery Act having come into force in 2010, bribery is still a hugely problematic issue in corporate life. Billions of pounds of fines are levied every year and frequent reports hit the headlines of investigations and prosecutions from the US Department of Justice and UK Serious Fraud Office.

Bribery cases have ensnared some of the world’s largest companies, biggest sporting bodies and most powerful politicians. The propensity for some people to act corruptly might never change, but our approach to training and compliance can.

VinciWorks has just released Anti-Bribery Fundamentals, a new anti-bribery course that will give employees the opportunity to understand the risks of bribery in their working life as well as to test their knowledge and understanding of the subject, and teach them how to avoid becoming ensnared in bribery.

In this course, we take the lessons from the last ten years of bribery in the corporate world and distill that into an action-packed half-hour course that combines real-life case studies, interactive games, relevant scenarios and a fully customisable course experience to make sure your bribery procedures are fit for purpose.

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The legal, ethical and reputational risk of bribery is real. Billions in fines are levied every year and frequent reports of investigations and prosecutions from regulating authorities across the world hit the headlines.

We were delighted to be joined by Head of the OECD’s Anti-Corruption Division Patrick Moulette and Transparency International’s Global Business Integrity Programme Lead Britta Niemeyer.

These leading international bribery and corruption experts discuss the challenges businesses face in building a strong anti-bribery and corruption programme in 2021, and give their insights into how businesses can best fight bribery.

The webinar covered:

  • Major anti-corruption and bribery cases and what we can learn
  • The impact COVID-19 has had on anti-bribery and corruption
  • The industries most vulnerable to bribery and corruption
  • Guidance for whistleblowers and how they are handled by authorities
  • Anti-bribery training requirements and best practice
  • Answering attendee questions

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How does your organisation collect and process gifts and corporate hospitality given to your staff? How do you track the gifts given by your staff to current or potential clients?

Globally, organisations are bound by complex and ever-changing legal obligations and industry-specific compliance requirements. Clients also often expect their professional service firms to have certain risk management procedures in place, such as gift registers and anti-bribery training. But without a structured and secure data collection system, organisations can waste time and resources trying to ensure compliance.

Omnitrack is VinciWorks’ solution to collecting, storing and managing data. The Omnitrack Gifts and Hospitality Register allows managers to receive instant notifications for all gifts given and received. This enables them to make informed decisions on the next steps, such as whether to approve or deny the gift in question.

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