Advanced Training - Bribery Act 2010 - Sample Module

Section 4 - Bribery Prevention


It is widely accepted that the best method of preventing fraud, bribery & corruption is not the potential punishment but the fear of detection. Furthermore the fear of informal sanctions (the shame and embarrassment in front of family, friends and peers) has been shown to be a greater preventative method than the fear of formal sanctions (punishment handed out by the judicial system).

Robust prevention procedures help increase the fear of detection. Similarly an organisation that makes it clear they that will not tolerate fraud, bribery and corruption and that any individual identified as being involved in such activities will be suitably punished will enhance prevention.

The following pages deal with some of the prevention policies and procedures that your organisation may consider and how they should be implemented.

The perception of detection can be increased by:

  • Employee education & fraud / bribery awareness
  • Confidential reporting facilities (whistle blowing)
  • Management oversight

Section 4 - Bribery Prevention

Risk Assessment

Almost every organisation is vulnerable to fraud and corruption including bribery. It is vital that in order to reduce this vulnerability that any weaknesses are identified and mechanisms put in place to prevent or detect fraudulent activities. A risk assessment should be an ongoing process that aims to identify and mitigate an organisations risk to both internal and external fraud and corruption.

There are many factors that effect the level of risk to an organisation such as:

  • The business sector
  • The operating environment
  • The effectiveness of its internal controls
  • The ethics and values of the owners and employees

The following factors will enhance the effectiveness of a risk assessment:

  • A good working knowledge of the business and inherent risks of bribery within the business sector concerned
  • An independent and objective approach
  • Access to all levels of personnel in the organisation
  • The mindset to believe that fraud and corruption may be present
  • The right sponsor
  • Managers and employees trust of the team undertaking the assessment

An important part of the actual risk assessment will be gaining information from personnel at all levels. Often it will not be viable or worthwhile to interview everyone therefore other methods such as focus groups and surveys (possibly anonymous) should be considered that may identify information not otherwise disclosed.

Example Anonymous Survey Question

If you found out that a colleague had requested a bribe from a contractor would you report the matter? If not why not?