Clear policies and guidance
Though having mechanism for check and balance is important, it is simply not enough. An organisation should have its own rules regarding corruption and bribery. The rules must be well written into documents called policies. Guidance is further instruction to implement the policies. The auditors will depend on these policies and guidance to report about the misconducts of in-charge officers. Without policies and guidance, every actions would be acceptable.
Regarding bribery and corruption, there are three policies that requires utmost attention:
- Gift and hospitality: This policy should set out the financial threshold of gifts that an officer could accept from a stakeholders and the procedure for receiving such gifts. Normally, every gift for officer because of his/her position should be rejected. If the officer cannot reject the gift due to circumstances, he/she must record and report back to line manager as well as risk officer/audit committee.
- Conflict of interest: The policy rules how an officer should act when he/she stands in conflict of interest situation. Usually the officer must disclose his relationships with relevant stakeholders and withdraw himself from the situation entirely.
- Transparency and record archive: This policies set out the documents that must be recorded and saved in archive for later audit.
Train the officers
Finally, the ethics of in-charge officers are not less crucial than policies or check and balance mechanisms. Fortunately, ethics can be learned.
The organisation leadership should develop a culture of trust and transparency. From here, the employees can learn the ethical practices from the leaders and their peers. Furthermore, any organisation can support their employee to finish the Ethical Certificate on CIPS website.