Anti-bribery compliance requires a much more robust approach than developing a simple stand-alone policy. Over and above the policy organisations need to develop anti-bribery processes, procedures and controls and implement these throughout their business. High risk areas may include gifts and entertainment, travel, donations, sponsorships, CSI, business partners, books and records, investments, JV's/mergers and acquisitions.
Organisations should understand that bribery remains a constant threat and they need to ensure that their adopted anti-bribery controls and procedures are in good working order. On-going monitoring and tweaking of their anti-bribery controls and procedures is essential and will help to remediate risks before they spread