Global Anti-Bribery Guidance

Best practice for companies in the UK and overseas

17. Monitoring & Review

Quick Read

Regular monitoring to ensure that the anti-bribery programme is effective is essential in order to drive continuous improvement, and to detect and deter bribery.

Monitoring and review contributes to the continuous improvement of the anti-bribery programme. It checks that the design is sound, implementation is effective and identifies areas for improvement. In addition, through early detection of 'red-flags' and potential incidents of bribery, such monitoring can act as a deterrent to bribery.

Monitoring and review can draw on a wide range of sources including the views of employees, internal systems and controls and internal and/or external audits of the relevant business area.  Senior management should regularly review how the anti-bribery programme is implemented and report on this to the Board of directors.

Key elements of best practice

  • Continuous improvement: Through monitoring the anti-bribery programme, identify aspects which could be improved or where the process and procedures could be simplified to ensure that the programme is as effective and efficient as possible. ¬†
  • Focus: Ensure close and regular monitoring of high-risk functions and transactions. As a safety control, use statistical sampling to select spot checks to avoid risks being overlooked.
  • New technology: Use technology to manage the monitoring process, enable collaborative working, record data and information, provide a monitoring/audit trail and carry out automated data analysis to monitor for red flags and suspicious transactions.
  • Independent review: Engage external independent reviewers to test and provide confidence in the anti-bribery programme, as well as provide a different perspective on existing processes and procedures and where improvements can be made.
  • Review by leadership: Report on results of monitoring to senior management and the Board and ensure that improvements are implemented where deficiencies have been identified.

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