Keith Read is an award-winning thought leader and expert in compliance, ethics, culture and governance. He was formerly the Group Director of Compliance and Ethics for BT (British Telecom) in London and is a past winner of the Compliance Register's Best Compliance Officer award, when he also won the Best Compliance Company award.
For teaching about ABC, I developed an exercise that I call the “Sliding Scale of Bribery,” based loosely around a speech given by Richard Alderman, then Director of the UK Serious Fraud Office (SFO):
The “Bribery Triangle” (above) is a simple but effective representation of the bribery process, and shows the three primary elements of the “Bribery Equation”— the three elements that can be used to reduce or remove bribery.
This simple approach attempts to consider the three key drivers of bribery: supply of funds, goods, favors, services, and/or other incentives for bribery; demand for bribery; and the environment to support bribery, which clearly includes culture at both ends of the bribery equation (i.e., the bribe payer and receiver).
In the Sainsbury’s supermarket bribery case, two directors at a potato supplier showered the supermarket’s potato buyer with gifts and hospitality in return for lucrative contracts. The judge in the case said it was “very nearly as serious a case of corruption as I can imagine” that involved Sainsbury’s being “bribed with its own money.” The supermarket says the total amount it was overcharged was £8.7 million. The bribery came about because the potato supplier wanted to keep the Sainsbury’s contract—45% of Sainsbury’s potato contract worth about £40 million.
How was this bribery allowed to come about?