There are many practical and relatively simple bribery controls that companies can put in place, but the sad fact is that most of them don’t. Again, this is partly because of misplaced belief (see above), but also because companies believe that such controls will restrict their business, create unnecessary overhead, constrain their ability to compete, and, in any case, are too difficult to implement and sustain. Companies also often believe that since they have put in place policies, procedures, and training, their work is done.
Anticipating and Closing Down Bribery Opportunities, Including Rotating Roles
There are some industries, countries, and sectors that present a potential high risk of bribery—and considered anticipation of such risks is a good example of active bribery control. However, in practice, most companies would see the risk of bribery as low on their priorities and, as a consequence, do not devote sufficient time and resources to such anticipation.
Bribery demands, agreements, and arrangements are invariably made using verbal communications, sometimes by phone and mostly face-to-face. Therefore, one technique for preventing bribery is to consider how technology, written communications, or other approaches can be used to “stand in the space” occupied by verbal and face-to-face communications. In this way, the opportunity to agree and arrange bribery can be closed down, or at least minimized.
If a company intends to focus on the realities of bribery, then it should consider whether there are other means of transacting business—including regularly rotated employees; more senior, different managers; and the use of more online interactions rather than personal interactions.
Interaction planning is another approach to closing down bribery opportunities and risks. For example, while facilitation payments may well remain a challenge for employees and goods passing through customs, increasing the use of security technology to screen both people and goods through airports may again help to “stand in the space” between customs officers and passengers and, as a consequence, increasingly close down the opportunity for bribery demands.
Similarly, effective pre-planning can serve to reduce bribery risks, and the pressures to meet those demands. Often, a bribery opportunity related to a customs or similar official will be driven by the fact that they know products, materials, and machinery will be delivered “just-in time”; to stay on track will require fast clearance, which then fuels the bribery “perfect storm.” Delivering earlier and even stockpiling can remove not only the perfect storm conditions for bribery, but also create logistical challenges for the customs and port operators, with the result that they have to authorize clearance—without bribery.