35 percent of respondents expect bribery and corruption risks to rise according to 2017 Anti-Bribery and Corruption Benchmarking Report, a joint study from Kroll and the Ethisphere Institute
Reputational concerns, personal liability worries, global regulatory enforcement, burgeoning number of third parties, and post-onboarding problems collectively highlight value of ongoing monitoring programs
Kroll, the global leader in risk mitigation and response solutions, together with the Ethisphere Institute, a global leader in defining and advancing the standards of ethical business practices, today released the 2017 Anti-Bribery and Corruption Benchmarking Report (“ABC Report”). The theme of this year’s ABC Report is “Beyond Regulatory Enforcement: The Rise of Reputational Risk.” Against a backdrop of heightened regulatory and reputational concerns, more than one-third (35 percent) of all risk and compliance professionals surveyed expect their organization’s bribery and corruption risks to increase in 2017, and more than half (57 percent) expect them to persist at the same levels as last year.
Respondents believe the top risks to their anti-bribery and corruption programs will come from third party violations (40 percent), a complex global regulatory environment (14 percent), and employees making improper payments (12 percent).
The reputational risk associated with bribery and corruption allegations is also on the minds of most respondents. Indeed, general reputational concerns went from being the least likely reason identified in last year's ABC Report for a third party to fail a company’s vetting standards to being the most likely reason — a stunning change in just one year.
“It is clear the anti-bribery and corruption program can be viewed in the context of regulation, as well as more broadly as a means of protecting an organization’s most valuable asset — its reputation,” said Steven Bock, Managing Director and Head of Operations and Research with Kroll’s Compliance practice.
In a related development, the survey data suggests senior leadership’s engagement regarding anti-bribery and corruption efforts is on the rise. Fifty-one percent of respondents state senior leadership at their organization is “highly engaged” with anti-bribery and corruption efforts, a 4 percent increase over the previous year.
“All research points toward a clear link between ethics and performance, and with more involvement from leadership, we are seeing that anti-bribery and corruption efforts are being prioritized,” added Erica Salmon Byrne EVP & Executive Director of Business Ethics Leadership Alliance, Ethisphere. “Smart companies with strong compliance programs are taking note and adjusting their priorities accordingly in order to mitigate unnecessary risk and protect their company’s valuable reputation for integrity.”
Another strong trend that emerged in this year’s ABC Report is the dependence on ongoing compliance monitoring to capture post-onboarding bribery and corruption issues. More than half (55 percent) of respondents report they identified legal, ethical, or compliance issues with a third party after conducting initial onboarding due diligence. In 40 percent of these cases, the issue that was later identified did not exist at the time of initial onboarding. The value of ongoing monitoring is reflected in the level of confidence that survey-takers have in their ABC programs. Nearly 80 percent of those respondents who monitor all of their third parties, regardless of risk profile, believe they are either extremely or appropriately prepared to address global bribery and corruption risks. Conversely, feelings of preparedness drop as the level of ongoing monitoring goes down.
“As compliance professionals, our respondents know the importance of monitoring when working with third parties. But this report highlights the need for an ‘interval monitoring’ approach to ongoing diligence, where the scope and frequency of monitoring efforts is determined based on risk,” said Kroll Senior Managing Director Joseph Spinelli.
“With vague regulatory guidance, optimal frequency is subject to interpretation,” adds Kroll Managing Director Robert Huff. “Firms need to determine a level of monitoring so they can react appropriately, in a timely manner, to any changes in a third party’s risk profile.”
The ABC Report also includes the following findings:
- 49% of respondents showed concern that they did not have enough resources to support anti-corruption efforts.
- One-third of respondents reported having a greater level of concern about personal liability than the prior year.
- 26% of respondents said issues that were identified at the time of third party onboarding were not adequately addressed.
- 67% of respondents reported engaging in M&A in 2016, but conducted lesser levels of due diligence on targets or targets’ third parties than expected.
- 37% of CFOs maintain an active role in developing their organization’s anti-bribery and corruption programs.
The 2017 ABC Report was publicly released today at Ethisphere’s Global Ethics Summit in New York, NY.
The full 2017 ABC Report can be accessed here
Notes to editors
Kroll and the Ethisphere Institute partnered to create the 2017 Anti-Bribery and Corruption Benchmarking Report. Senior Ethisphere analysts and Kroll partners created the survey in October and invited senior-level executives working in ethics, compliance, or anti-corruption worldwide to respond. The survey was open from November 17, 2016 to February 7, 2017.
The survey produced 388 complete and partial responses. Nearly half of respondents (44 percent) represented publicly listed companies; an additional 43 percent represented privately held companies, and 13 percent identified their organizations as a non-profit or other type of organization. The majority of organizations were headquartered in North America (43 percent), followed by the United Kingdom (14 percent), Western Europe (14 percent), Brazil (8 percent), and Australia/New Zealand/Pacific Islands (7 percent).
Thirty percent of respondents held the title of compliance and ethics officer or chief compliance officer, followed by director (17 percent). A wide range of other titles trailed closely behind, all of them related to compliance or anti-corruption activities.
Respondents represented a wide range of industries; the largest industry group was manufacturing, followed closely by finance and insurance (each at 17 percent).
The median worldwide employee headcount of the qualified respondents was 1,000 to 9,999, while the median revenue segment was $1 billion to $5 billion.
This was a self-reported survey from Kroll and Ethisphere’s audience of ethics and compliance professionals, and Ethisphere did not attempt to verify or audit the data reported by survey-takers.
About Kroll
Kroll is the leading global provider of risk solutions. For more than 40 years, Kroll has helped clients make confident risk management decisions about people, assets, operations, and security through a wide range of business intelligence and investigations, cyber risk, due diligence, and compliance, physical, and operational security and data and information management services. Headquartered in New York with more than 35 offices in 20 countries, Kroll has a multidisciplinary team of nearly 1,000 employees and serves a global clientele of law firms, financial institutions, corporations, non-profit institutions, government agencies, and individuals.
About Ethisphere
The Ethisphere® Institute is the global leader in defining and advancing the standards of ethical business practices that fuel corporate character, marketplace trust, and business success. Ethisphere has deep expertise in measuring and defining core ethics standards using data-driven insights that help companies enhance corporate character. Ethisphere honors superior achievement through its World’s Most Ethical Companies® recognition program, provides a community of industry experts with the Business Ethics Leadership Alliance (BELA), and showcases trends and best practices in ethics with Ethisphere Magazine. Ethisphere is also the leading provider of independent verification of corporate ethics and compliance programs, including Ethics Inside® Certification and Compliance Leader Verification™. More information about Ethisphere can be found at: http://www.ethisphere.com.
Respondents believe the top risks to their anti-bribery and corruption programs will come from third party violations (40 percent), a complex global regulatory environment (14 percent), and employees making improper payments (12 percent).
The reputational risk associated with bribery and corruption allegations is also on the minds of most respondents. Indeed, general reputational concerns went from being the least likely reason identified in last year's ABC Report for a third party to fail a company’s vetting standards to being the most likely reason — a stunning change in just one year.
“It is clear the anti-bribery and corruption program can be viewed in the context of regulation, as well as more broadly as a means of protecting an organization’s most valuable asset — its reputation,” said Steven Bock, Managing Director and Head of Operations and Research with Kroll’s Compliance practice.
In a related development, the survey data suggests senior leadership’s engagement regarding anti-bribery and corruption efforts is on the rise. Fifty-one percent of respondents state senior leadership at their organization is “highly engaged” with anti-bribery and corruption efforts, a 4 percent increase over the previous year.
“All research points toward a clear link between ethics and performance, and with more involvement from leadership, we are seeing that anti-bribery and corruption efforts are being prioritized,” added Erica Salmon Byrne EVP & Executive Director of Business Ethics Leadership Alliance, Ethisphere. “Smart companies with strong compliance programs are taking note and adjusting their priorities accordingly in order to mitigate unnecessary risk and protect their company’s valuable reputation for integrity.”
Another strong trend that emerged in this year’s ABC Report is the dependence on ongoing compliance monitoring to capture post-onboarding bribery and corruption issues. More than half (55 percent) of respondents report they identified legal, ethical, or compliance issues with a third party after conducting initial onboarding due diligence. In 40 percent of these cases, the issue that was later identified did not exist at the time of initial onboarding. The value of ongoing monitoring is reflected in the level of confidence that survey-takers have in their ABC programs. Nearly 80 percent of those respondents who monitor all of their third parties, regardless of risk profile, believe they are either extremely or appropriately prepared to address global bribery and corruption risks. Conversely, feelings of preparedness drop as the level of ongoing monitoring goes down.
“As compliance professionals, our respondents know the importance of monitoring when working with third parties. But this report highlights the need for an ‘interval monitoring’ approach to ongoing diligence, where the scope and frequency of monitoring efforts is determined based on risk,” said Kroll Senior Managing Director Joseph Spinelli.
“With vague regulatory guidance, optimal frequency is subject to interpretation,” adds Kroll Managing Director Robert Huff. “Firms need to determine a level of monitoring so they can react appropriately, in a timely manner, to any changes in a third party’s risk profile.”
The ABC Report also includes the following findings:
- 49% of respondents showed concern that they did not have enough resources to support anti-corruption efforts.
- One-third of respondents reported having a greater level of concern about personal liability than the prior year.
- 26% of respondents said issues that were identified at the time of third party onboarding were not adequately addressed.
- 67% of respondents reported engaging in M&A in 2016, but conducted lesser levels of due diligence on targets or targets’ third parties than expected.
- 37% of CFOs maintain an active role in developing their organization’s anti-bribery and corruption programs.
The 2017 ABC Report was publicly released today at Ethisphere’s Global Ethics Summit in New York, NY.
The full 2017 ABC Report can be accessed here
Notes to editors
Kroll and the Ethisphere Institute partnered to create the 2017 Anti-Bribery and Corruption Benchmarking Report. Senior Ethisphere analysts and Kroll partners created the survey in October and invited senior-level executives working in ethics, compliance, or anti-corruption worldwide to respond. The survey was open from November 17, 2016 to February 7, 2017.
The survey produced 388 complete and partial responses. Nearly half of respondents (44 percent) represented publicly listed companies; an additional 43 percent represented privately held companies, and 13 percent identified their organizations as a non-profit or other type of organization. The majority of organizations were headquartered in North America (43 percent), followed by the United Kingdom (14 percent), Western Europe (14 percent), Brazil (8 percent), and Australia/New Zealand/Pacific Islands (7 percent).
Thirty percent of respondents held the title of compliance and ethics officer or chief compliance officer, followed by director (17 percent). A wide range of other titles trailed closely behind, all of them related to compliance or anti-corruption activities.
Respondents represented a wide range of industries; the largest industry group was manufacturing, followed closely by finance and insurance (each at 17 percent).
The median worldwide employee headcount of the qualified respondents was 1,000 to 9,999, while the median revenue segment was $1 billion to $5 billion.
This was a self-reported survey from Kroll and Ethisphere’s audience of ethics and compliance professionals, and Ethisphere did not attempt to verify or audit the data reported by survey-takers.
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