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12 Steps to Better Anti-Bribery and Corruption Compliance

2019-04-28 10:21 Sunday

The Australian Trade Commission (Austrade) issued a guidance for Australians doing business overseas in 2018, providing practical guidance for establishing a culture of compliance and managing bribery and corruption risks within organizations.


The report, released in September 2018, highlights 12 key steps in developing an effective anti-bribery and corruption (ABC) compliance plan.

Why is it important for Australian companies to have an effective ABC program?

Bribery and corruption are serious risks for Australians doing business abroad. Bribery of a foreign public official is a serious crime under Australian law, and the penalties vary depending on the individual or company involved.

For individuals, the maximum penalty is 10 years' imprisonment or a fine of 1.8 million Australian dollars. For the company, the maximum fine is three times the profit, or 10% of the company's annual turnover, or 18 million Australian dollars.

Australia and Australian companies engaged in such activities could be subject to multiple foreign and domestic legal actions in multiple jurisdictions.

The Austrade provides 12 steps to develop an effective ABC compliance plan, but it is worth noting that while this is a very useful guide, companies should still seek independent legal advice to ensure that they comply with all applicable laws.

The 12 steps to follow ABC include:

­ 1. Commitment from the Top

­ 2. Design A Program

­ 3. Monitor the Program

­ 4. Drafting ABC Policies

­ 5. Develop Detailed Policies and Procedures

­ 6. Apply Your Application to Business Partners

­ 7. Whether There Are Internal Controls and Records

­ 8. Communication and Training

­ 9. Incentive Moral Behavior

­ 10. Seek Guidance, Find and Report

­ 11. Solve the Infringement

­ 12. Review

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