Leadership by example: leaders should foster a culture of integrity where ethical behaviour is valued and bribery is unequivocally condemned.
Anti-Bribery Management System, a framework for ethical organisational conduct from top down
THE phrase “a fish rots from the head down” aptly describes how it applies to organisations when it comes to preventing criminal acts, including corruption, regardless of their adoption of standards, systems, or certifications to avoid such occurrences.
Leadership plays a crucial role in adopting measures that establish ethical credibility through independent validation of an organisation’s adherence to global standards in its business activities.
Notably, even the slightest wavering or lack of firm commitment from an organisation’s top management can reduce a robust, internationally recognised system such as the ISO 37001 Anti-Bribery Management System (ABMS) to mere paper formalities.
In other words, the ABMS has been reduced to being a mere corporate showcase, with little dedication or willingness to fully implement the control mechanisms established as the organisation’s anti-bribery compliance framework.
Setting a robust foundation
From the outset, the ABMS provides organisations with exactly this framework.
Organisations look to ABMS to assist them in establishing, implementing, maintaining and improving an anti-bribery compliance programme designed for the primary goal of preventing, detecting and responding to bribery.
Once the framework is completed, the main focus for the organisation with the ABMS will then shift to implementation, which is centred on three main thrusts to achieve its goal. They are:
> Prevention: To inculcate the culture of integrity and transparency, establish policies, procedures and controls. This includes the training of employees, conducting risk assessments and ensuring that all business operations are conducted ethically.
> Detection: This is done through constant monitoring and auditing, encouraging whistleblowing and setting up reporting channels that allow employees and other stakeholders to report suspicious activities without the fear of retaliation and response.
> Response: Prompt and effective—demonstrated by conducting thorough investigations, taking the necessary corrective actions and cooperating with law enforcement agencies at the earliest possible opportunity.
All of these require an organisation to have a comprehensive belief in the objectives of the ABMS and full commitment in adhering to its practices, processes and procedures, especially in its controls and reporting mechanisms.
In corporate terms, it is essential for everyone to embrace this framework, encompassing the top management down to the lowest-ranking staff and personnel.
However, this top-heavy nature of the ABMS’ authority levels and control means that the reporting, formal as well as whistleblowing, will flow from the lower to the upper authoritative tiers in the organisation in accordance with the hierarchical structure, be it business units, sections, departments and even subsidiaries.
Perpetrators of corrupt and criminal acts will do everything they can to prevent these exposures from reaching the eyes and ears of those responsible for stopping such acts.
Hence, it is critical for the top management to have unwavering, iron-clad, zero-tolerance and uncompromising commitment, thereby ensuring it cascades seamlessly throughout the entire organisation.
Measures for improvement
The continued allegations and arrests by the authorities—including those from SIRIM’s clients certified under the ABMS—reflect the ongoing challenge of combating corruption, even among organisations that have declared their commitment to the high standards of ethical conduct.
No doubt, certification does not provide an absolute guarantee against acts of bribery.
ABMS, however, provides organisations with the built-in mechanism for continuous improvements in the matter through several measures. These include:
> the strengthening of internal controls to close gaps that will allow bribery to occur;
> the fostering of a culture of integrity where ethical behaviour is valued and bribery is unequivocally condemned;
> enhancement of transparency in the operations and decision-making processes to reduce opportunities for corrupt practices;
> supporting and protecting whistleblowers by providing anonymity channels, as well as the prompt addressing of such reports.
An effective tool
The ABMS, guided by the ISO 37001 standard, provides a robust framework for organisations in their effort to combat acts of bribery.
It is an effective tool for organisations that are fully committed towards utilising the ABMS’ mechanisms and controls to uphold the highest ethical standards and practices.
It helps to foster an environment of integrity and accountability throughout the organisation’s structure, from top to bottom.
Partnering with certification bodies such as SIRIM QAS International further strengthens these efforts, providing independent validation and credibility to their anti-bribery initiatives.
SIRIM QAS International provides certification services for various management systems, including ABMS.
By offering such certification, SIRIM QAS International helps organisations demonstrate their commitment to anti-bribery principles and compliance with relevant laws and regulations.
“This certification can improve an organisation’s reputation, reduce risks associated with bribery, and ensure a more ethical business environment.
“Promoting ethical leadership and fostering a culture of integrity are essential in our commitment to combat corruption and uphold the highest standards of ethical conduct across all sectors,” said SIRIM Bhd president and group chief executive officer Datuk Dr Ahmad Sabirin Arshad.
While rot may start from the head, or elsewhere, it shouldn’t be allowed to infect the whole body.
This article is brought to you by SIRIM QAS International.