Assessing bribery and corruption risks

These questions can help you assess whether your business may be at risk of breaching bribery and corruption laws in New Zealand and overseas.

  1. Is there a strong message of 'zero tolerance to corruption' from those at the top of the organisation (directors and senior management)?
  2. Is the organisation operating in any high risk jurisdictions (refer to Transparency International's Bribery Payers and Corruption Perceptions Index) or high risk sectors (e.g. defence, oil and gas, property development, shipping)?
  3. Do you have a comprehensive code of conduct which must be signed by staff and agents in all countries where the organisation is operating?
  4. Are system processes and internal controls in place to support the code of conduct (in particular: clear procedures on gifting/corporate hospitality/entertainment, staff training and whistle-blower protection)?
  5. Do you have a dedicated position (such as a compliance officer) with overall responsibility for the organisation's anti-corruption programme across all countries?
  6. Are staff actually implementing the organisation's anti-corruption policies?
  7. Are employees circumventing established organisational processes or arguing special cases?
  8. Do employees have an unusual interest in a particular contract or a specific contractor?
  9. Is an employee's lifestyle at odds with their known level of income? 
  10. Are you fully aware of activities of your overseas agents (for example, no indication of 'splashing the cash' to attract business)?

For a more detailed list of warning signs of bribery and corruption, see What to watch for.