Corruption

 

Role of Senior Managers, Intermediaries & Gatekeepers in Foreign Bribery-2020 OECD Report

Many years of foreign bribery enforcement have proved that in a vast majority of cases, bribes are paid, offered, or promised through a senior manager or an intermediary. Those are just some of the latest findings issued by the September 2020 OECD report "Foreign bribery and the role of intermediaries, managers and gender", which analyzes data from anti-bribery enforcement actions around the world ( OECD Report).

To better understand how companies bribe foreign officials and in turn better predict and mitigate risks, it helps to know what kind of individuals perpetrated the malfeasance. This information is crucial in helping companies design adequate compliance programs, focusing their efforts where it matters most.

Senior Management

One of the most alarming results reinforces the need for training and audits at every hierarchical level of a company. The OECD report demonstrates that senior management is the hierarchical level of individuals most frequently involved in bribery committed by a company. In fact, in 75% of the cases (87 out of 115), a senior manager was involved in the scheme. In a majority of cases, the offense involved more than one individual within the same company. These findings confirm that senior leadership is often aware of, if not directly involved in, corrupt activity.