Driving forces in Anti-Bribery and Corruption: Increased Awareness and Structured Legislation   

Anti-Bribery and Corruption (ABC) is more and more present in the media and in the public discussion. Despite the growing media attention and publications, such as Corruption Perceptions Index that is published annually by the Transparency International, it seems that the public still has a very limited view on bribery and corruption.

ABC is one growing area of interest and BearingPoint has been developing capabilities to support and advice our clients to enhance internal controls and awareness. ABC capabilities compliment BearingPoint’s offering portfolio to ensure a more robust risk management.

We sat down with Sanna Kalliokoski from Code of Conduct Company to discuss about ABC especially in the Finnish context and from an ethics and social responsibility perspective.

Sanna Kalliokoski is a GRC specialist at Code of Conduct Company. Her background is in the financial sector, lastly within compliance and risk management. Code of Conduct Company is a boutique consulting firm helping organizations, working with projects especially concerning social responsibility and good governance, advance responsible corporate culture and ethical business conduct. The driving force behind Code of Conduct’s work is the vision for a more responsible, fair, and humane working life.

Regulation in Finland and organizational awareness

The Finnish legislation does not have one comprehensive ruling act for ABC, compared to for example the act on money laundering and terrorist financing which are governed in the AML Act. However, having a more effective anti-bribery and corruption framework does not necessarily mean having one ruling regulation. Kalliokoski reminds that corruption cannot be stopped only with legislation, but a better structure in the Finnish legislation would enable better prevention especially in an international context. Additionally, she mentions that actions from the European Union (EU) would support in establishing an aligned level in the EU member states. 

Companies and organizations have usually two driving factors to improve their awareness of ABC and to educate their employees: external or internal pressure.

Sanna Kalliokoski, Code of Conduct Company

“ABC policies and programs have become the norm in international business and thus give pressure to companies and their management, who seek out to their partners for similar awareness level”, Kalliokoski continues. The maturation of the awareness level can be achieved by many different activities. Typical ways to increase awareness, according to Kalliokoski, are admitting, that corruption is a part of the business culture, ensuring internal expectations and practices are documented and trainings provided. It is crucial to understand that corruption entails more than just bribes.

“The focus of trainings can vary depending on the industry but receiving training and having the right tone from the top is crucial for the successful ABC awareness maturation”, Kalliokoski says and continues with a practical example of the change. “Compliance Officers are more often titled as Ethics & Compliance Officers. This is one sign of the progress in ethics and in the overall awareness level.”

Does the maturing anti-bribery and corruption level have an impact on how people and organizations operate? 

"Writing a policy does not prevent bribery or corruption”, Kalliokoski replies.

The culture of a company is crucial; what is acceptable and what is not. Kalliokoski mentions customer relationships as one practical implication of anti-bribery and corruption work. “One of the most challenging situations are with existing customer relationships. If accustomed ways of working are changed and/or possible freebies taken away that have been there for years, what is the impact to the customer and to the whole customer relationship?” 

Thus, a more holistic approach to anti-bribery and corruption awareness is needed in society. “Transparency and awareness in society and within companies increases the possibility to detect and to prevent other criminal activities as well”, Kalliokoski describes.

Future trends

When discussing the future trends of ABC, Kalliokoski believes that changes in regulation and increased awareness will continue to be driving factors. Sudden changes in society and across the world will also play a major role. Kalliokoski mentions that working from home has had an impact and will continue to have on people, companies and organizations. She also addresses the recent challenges in supply chains and the sharply increased inflation: “When the economic situation gets worse, fraud, corruption and unethical conduct attempts increase. For example, employees desperately try to reach their targets and there is more of an incentive for companies to smoothen the troublesome supply chains.” 

On the positive side it should also be noted that, according to Kalliokoski, technology is evolving, and younger generations are more in tune with the ethical approach, which helps the fight against bribery and corruption. "After all, good morals are the best ABC program we will ever have”, she concludes.

How can BearingPoint help your organization?

Bribery and corruption are a global problem. Therefore, the anti-bribery and corruption measures must be relevant, sustainable and continuous – not only a tick-the-box exercise done once. See the first part of our blog series related to Anti-Bribery and Corruption here.

How is your organization prepared to identify and stop bribery and corruption? Has your company assessed potential risks, outlined key controls and ensured that a risk mitigation plan is up to date? Is your company’s risk assessment taking these into consideration?

BearingPoint is an independent management and technology consultancy with global reach and operating in three business units: Consulting, Products, and Capital. With our support, clients are able to achieve measurable and sustainable success both locally and globally. 

In Finland, the Anti-Financial Crime (AFC) practice has been growing rapidly over the past couple of years and provides AFC consulting in areas such as Know You Customer (KYC), Transaction Monitoring (TM), Sanctions, Fraud, Anti-Bribery and Corruption (ABC), and Operational Excellence (OE). A team of experts has been co-operating with clients by creating AFC fundamentals and frameworks, enhancing existing AFC capabilities, processes and tools, and building up the risk management function and maturity level of the organization. 

Working together with our client, BearingPoint is able to provide and utilize its deep experience and market knowledge. This enables a dynamic way of working where the assessment, development and implementation of solutions are tailored to fit our customer’s needs. 

 Contact us for more information: 

Henrika Pelkonen
Senior Business Consultant, BearingPoint Finland

Timo Törrönen
Business Advisor, BearingPoint Finland