“I know I have a robust compliance program, one which would satisfy the regulators, but what keeps me up at night is the issue of whether or not it is understood and taking hold in the field.” Compliance Executive, 2015, at a Compliance Symposium.
The front line of international business has never been a more complicated and potentially hazardous environment in terms of the potential confrontation with corruption risk. Given the enforcement environment in the US, UK, as well as other countries, plus the growing anti-corruption movement in regions that have had historically little to no regulation, it has never been more critical that front line business teams receive a consistent anti-bribery message. But what are the challenges in developing a compliance regime that can be embraced at the field level of international business?
Front-Line Anti-Bribery LLC is a consultancy which looks to engage with organizations that seek to enhance their compliance efforts beyond the traditional “bolt-on” set of rules and procedures. As a complement to existing legal, audit and regulatory compliance, I seek to assist in the identification of both “spoken and unspoken” organizational messages, including forecasts and compensation, that might perhaps cause confusion at the field level with “what does management really want.” I also look at ethical behaviors and messaging as potential red-flags of decision making. I help to identify aspects of training, which if enhanced, might better provide those at the field level with a deeper understanding of why bribery is never a “win-win,” which is an illusion too often embraced at the front-lines of international business.
Having spent the better part of ten years living and traveling in high-risk areas through the “dark side” of international business, I share my own perfect storm of “rationalizing bribery” as a unique perspective to help organizations better understand how corruption is confronted at the field level of international business, in order to develop tools which are better calibrated to those realities.
The risk of corruption in the field remains great, and corporate personnel are tasked with business growth in high-risk areas, often working among corrupt local officials, third parties, and other entities. Keeping those in such environments on the ethical “right side” does not happen without engagement, understanding and training. Front-Line Anti-Bribery LLC is centered on helping organizations with those “where to start” moments and the comfort that you can “fix what you know.”
While you might have a robust compliance department and program, is it understood at the front-lines of business where rules, policies and procedures meet the behaviors? My experience and journey is there to help you calibrate those programs to such realities.
In other words, how can a corporation insure that the front line international business teams are highly successful and rewarded both individually and corporately while embracing an anti-bribery program and ethic? It can be done, but you need to first look at compliance from the perspective of how it appears at the field level.
Please feel free to e-mail me here at [email protected], to see if Front-Line Anti-Bribery can complement your existing compliance efforts, and for a portfolio of prior writing and speaking engagements.