Ground-Breaking Work: Effectiveness Testing your Anti-Corruption Programme Using Metrics

We just finished conducting a region-wide test for a major company across nine entities using a unique combination of activity and impact metrics tailored to the organisation’s own operations. Here’s how we did it.

1.?????? Select the right metrics. The first stage was to understand the operation and check their corruption risk assessment. This helped us identify a set of proposed anti-bribery and corruption (ABAC) metrics from the bank of potential metrics we have built up over several years of research. We then went through a review exercise with the operating companies and identified those which all the companies could provide. This formed the set of metrics we were going to work with.

2.?????? Gather the data. The data came from various sources: audit information, training records, meeting minutes and other internal reports. Perhaps most importantly, we ran an integrity survey (using the client’s own platform in this instance) which produced some of the most important impact metric information. The results of the survey really showed us what people across the entire organisation thought about the area of corruption, including how willing they were to report corruption incidents, whether they thought their managers acted with integrity or if they thought it was acceptable to give a gift to a government official. The data was weighted according to how much impact it would really have on corruption risk. For example, general communications on anticorruption received a low weightage, while any instances of corruption reported in the public domain would have had a high weightage (fortunately there were none).

3.?????? Produce the charts, graphs and key data points for reporting. The data was input into a mathematical model to produce the tremendously valuable figures, charts and other materials which we were going to use to present the results. This took some time as we worked with the Group Compliance Department to get the format just right. An example of the kind of result we would produce can be seen below.

One crucial area which the metrics-based approach identified was the level of integrity in the company culture. The culture of the company is akin to its operating system: though intangible and unseen, it governs pretty well everything which goes on. Using the metrics incorporated in the programme we were able to identify key data points of the organisation’s culture in relation to ABAC and integrity. This proved to be particularly interesting to some of the C suite and directors who wanted to see the company from a new perspective. Previously, very high scores had been achieved due to the intensive work which had been done, but those assessments largely used activity metrics (e.g. 100% of staff had attended training online) but not impact metrics which showed whether the intended result had been achieved, e.g. whether it was acceptable to receive a hamper from a supplier (the correct answer was No).?

4.?????? Socialise the report, engage with top management and the board. For each operating company we presented their results, first to the compliance team and then to their CEO. These reports were very detailed and gave specific data on the strengths and weaknesses of their programme and what action should be taken to address the areas needing improvement. An in-depth discussion ensued from each presentation as the CEO and Head of Compliance discussed how to use the results to move forward. Once the Opco CEOs had been engaged we also presented the results to the Group CEO, who similarly wanted to explore how to strengthen the programme further on a group-wide basis. Recognition was also given to the compliance team for all that they had achieved, which the report identified on a factual basis.

Following the Group CEO engagement we presented a summary of the report to the Board Risk committee. This also resulted in an extensive discussion on the new insights the report presented and how best to proceed and what additional resources might be needed.

Overall, the assessment proved to be highly successful in orientating both the individual companies and the group’s board on the current status of their ABAC programme. It provided assurance to the board on the integrity health of the company, based on the assessment of an independent external party using metrics tailored to the specific nature of the organisation.

Furthermore, now that the initial report has been completed, the exercise can be re-run on an annual or biannual basis to show the improvements. In this way the performance of the ABAC system can be measured on a year-on-year, factual basis.

Taking a proactive approach in this groundbreaking way has enabled the Compliance department to gain a clear picture on a facts basis on how well they are doing, together with specific pointers on where attention is needed to maximise the value and impact of the ABAC programme using the resources available.

If you’d like to understand more what we did, please email me at [email protected]. I’ll be happy to explain more about our methodology and how we could conduct a similar assessment for your company.