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4. Results: Answers
Anti-Corruption & Bribery
Tips and traps
What are your top tips for the smooth implementation of a robust anti-corruption compliance programme and what potential sticking points would you highlight?
United Arab Emirates
  • Build the compliance programme on ethical foundations:
    • Both shareholders and employees will appreciate an ethical compliance programme, as it demonstrates that the company is ethical at heart and has not merely established a compliance programme for the sake of compliance.
    • An ethical compliance programme that explains the ethics behind the compliance points will resonate more with various stakeholders, making it easier to secure buy-in.
  • Ensure that the compliance programme is easy to understand:
    • All documents in which the compliance programme is set out must be drafted in an easy-to-read format using simple language.
  • Consistently develop the compliance programme:
    • The compliance programme cannot be a static programme without room to evolve; it rather must evolve over time, as the business evolves and as laws and regulations evolve.
    • Ensuring that the programme is revised relatively often and keeps up to date with current laws and regulations will help to ensure stricter compliance by the company.
  • Cover important areas:
    • For small companies, implementing a compliance programme is by nature far simpler than for large companies.
    • As a company grows, it becomes harder to ensure that the compliance programme is covering all aspects of the business. This can result in extremely detailed and lengthy compliance programme requirements, which become more difficult to follow.
    • By ensuring that the compliance programme is streamlined and covering important areas such as regulatory risks, document retention, trailing and other tools that can assist, there is a greater chance that the compliance programme will be understood and thus followed by all employees.
  • Provide training:
    • As described in question 7.1, a compliance programme must include details of training and available tools to be used to ensure compliance.
    • It is no good simply covering the programme in general; specific training on relevant areas of the programme, as well as how employees should implement, must be provided on a regular basis.
  • Ensure that the compliance programme is implemented for all employees:
    • The compliance programme must include all levels of employees, from top to bottom.
    • If management are not included in compliance programme enforcement or training, there is a substantial risk that they themselves will fail to understand it fully and furthermore their blasé attitude may filter down to other employees.
    • Involving the CEO in the compliance programme and training will set a good example to employees on how they should operate and the importance of the compliance programme.
  • For more information about this answer please contact: Nadim Bardawil from BSA Ahmad Bin Hezeem & Associates LLP
    Anti-Corruption & Bribery