What are the guidelines and qualifications for ISO 37001:2016?

To many bribery cases are in the headlines, but all of these provide lessons for business leaders around the world. As reported in the Industry resource, Alere Inc., a global manufacturer of rapid point-of-care diagnostic tests, will pay more than $13 million to settle charges that it bribed foreign officials and committed accounting fraud to meet revenue targets. What are the guidelines and qualifications for ISO 37001:2016?

The U.S. Securities & Exchange Commission imposed the order, based on the fact that “Alere subsidiaries in India and Colombia ‘obtained or retained business’ by using distributors or consultants to make improper payments to officials of government agencies or entities under government control,” Industry resource reported.

The article states:

“In Colombia, improper payments of about $275,000 helped Alere win business from a government-linked customer. In India, the Alere unit through a distributor paid local governmental officials a four percent commission to increase orders for medical testing kits from 200,000 to 1 million units.”

The company allegedly netted millions for its efforts. It’s against this backdrop that it becomes clear that training and certification to prevent bribery and corruption is crucial for organisations today. For anyone doing business across international borders, it is critically important to be in full compliance and proactive in prevention and detection. But what are some of the requirements and guidelines for pursuing ISO 37001:2016 certification? Here, we address the most pertinent questions:

What are the training and certification guidelines set up by ICA?

ICA provides knowledge about anti-corruption as whole and bribery as a subset. It defines how bribery/corruption takes place and affect an organisation.

Which regulations does the ISO training specifically address?

ISO 37001:2016 training addresses the Foreign Corrupt Practices Act (FCPA) UK Bribery Act, among others.

How long is the certification valid?

How often you should update if needed? The certificate is valid for three years. It should be updated, however, if there is a change in the standard that would require additional training.

Why is it necessary to be certified by an accredited body like CRI Group’s ABAC Center of Excellence?

Certification through a qualified and endorsed firm of experts like CRI Group adds a distinct level of credibility to the organisation’s management systems, and ensures that the organisation is implementing a viable anti-bribery management program utilising widely accepted controls and systems.

It also provides assurance to management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. Most importantly, training and certification through a third-party like CRI Group protects your organisation, its assets, shareholders and directors from the effects of bribery. And, if needed, it provides acceptable evidence to prosecutors or courts that the organisation has taken reasonable steps to prevent bribery and corruption.

Who is CRI Group?

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

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CEO Clubs Pakistan has coffee with CRI Group’s CEO

CRI Group’s CEO Zafar Anjum has been invited to have coffee with CEO Clubs Pakistan. Called a “Trillion Dollar Club”, CEO Clubs Network holds high-level delegation visits to various countries to meet distinguished business figures, community leaders & government officials of certain countries and introduce or be introduced of Investment and Partnership Opportunities, Joint Ventures, Mergers etc. Click below and watch the coffee session now!

CEO Clubs Pakistan is a Chapter of the CEO Clubs Network Worldwide, a membership-based by invitation only Club and the largest business networking Club where members get connected with over 16,000 CEOs & senior executives across various industries globally. Being focused on business connection & development, therefore we strive to provide excellent business platform with unique opportunities for Club’s members expanding their businesses.

CEO Clubs Network Chapters are and have links in more than 25 countries. Our members are business elites, diplomats and government officials gathered together to exchange knowledge, share experiences, industries insights and trends. CEO Clubs Network creates diverse and multi-cultural atmosphere through its regular exclusive member gatherings in Dubai and other parts of the world with strong networking power and B2B connections which speed up business development for our members.

Who is CRI Group?

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

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ISO 37001: Applying Anti-Bribery Framework to Third Parties

In 2016, responding to the need for a global standard to help organisations prevent and detect bribery and corruption, the International Organization for Standardization (ISO) introduced ISO 37001: Anti-Bribery Management Systems. This certification provides the anti-bribery framework for organisations of any size or industry to implement practical solutions against bribery. Perhaps overlooked, however, is the fact that ISO 37001’s framework isn’t designed only for an organisation’s own internal systems. It can also be applied to existing or potential third-party partners. This adds a crucial layer of third-party due diligence and risk management in today’s world of international business.

The ISO 37001 Framework

Corporations, agencies, and even small companies don’t exist in a bubble. The reality of international trade and the interconnectedness of business make the potential for bribery and corruption a serious and continuous concern. While there are laws that govern business conduct along these lines, such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010, prior to 2016 organisations lacked a unified standard to help them implement proper controls for prevention and detection. This was a critical vulnerability, considering new laws in various jurisdictions were prescribing heavier penalties, and governments were, by and large, pursuing more enforcement actions.

Recognising this need, ISO unveiled 37001 with a twofold approach: Provide a practical, measurable system that organisations can implement to prevent and protect fraud; while keeping the system flexible and adaptable to fit any industry or jurisdiction. ISO was uniquely positioned to develop such anti-bribery framework with its reputation, having been in the standards business since 1947; and its global reach, which includes 164 member countries. Click here to read the full article.

Don’t let corruption thrive. Take a proactive stance with the highest level of compliance as a part of your essential business strategy. Contact us today to learn more about our full range of services to help your organisation stay protected. Get a FREE QUOTE

About CRI Group!

Based in London, CRI Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.[/accordion_son][/accordion_father][/vc_column][/vc_row]

Filed under: Anti-Bribery Anti-Corruption Solution, ISO 37001, Resources, Third-Party Risk Management by admin
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Effective leadership during COVID-19: a guide for leaders

Strong and effective leadership during a crisis is key

COVID-19 and its rapid global spread have quickly eclipsed in size and scope. In addition to the human toll and the economic damage, coronavirus has significantly changed the business landscape beyond recognition. In the face of COVID-19 specific challenges and still-uncertain risks, business leaders are rightly concerned about how their organisation will continue to be affected. And what can they do next? However, there are several lessons from history, a pooled of fundamental qualities of effective leadership and leading practical practices that chief executives should consider.

COVID-19 impact on companies varies by geography and sector companies in different ways. Their reaction capabilities have put businesses at different phases of dealing with the outbreak and, therefore, the impacts. However, regardless of the extent of COVID-19 effect on an organisation, we believe that five fundamental qualities of effective leadership distinguish successful CEOs from the rest:

Five fundamental qualities of effective leadership

 As a leader trying to guide your organisation through the COVID-19 crisis, it is essential to take specific steps that can help soften up the crisis’s impact—and enable your organisation to emerge stronger.

1. Build Positive/Trusting Relationships with a rationale
2. Clarify the direction and stick to it
3. Aim for decisive actions with courage
4. The Power of a Clear Leadership Narrative
5. Champion long-view Change

Take specific tactical steps to elevate your business

Any business during a crisis such as COVID-19 goes through three phases: mitigation, or lessening the force or intensity of the crisis and how the company deals with the present situation and manages continuity; preparedness, during which a company learns with a concrete research-based set of actions that are taken as preventive measures for a post-COVID-19 and emerges stronger; and future-proofing, where the company prepares for and shapes the “next to normal.” CEOs have substantial and added responsibility to nimbly consider all three-time frames concurrently and allocate resources accordingly.

Within these broad imperatives, effective leaders can take specific tactical steps to elevate these qualities during the current crisis, blunting its impact and helping their organisations emerge stronger. This crisis can become an opportunity to move forward and create even more value and positive societal impact, rather than just bounce back to the status quo with the right approach.

The secret of effective leadership: Foresee the unforeseen

The outbreak of COVID-19 was an unpredictable crisis with extreme consequences, and its westward March across the planet have introduced a new kind of unforeseen risk:

• Since World War II, all the recessions have been caused by either economic policy mistakes, oil shocks, or financial bubbles – and the CIVID-19 is a new category on its own: a global societal collapse.
• The mass quarantining across the globe cut off consumption, stopped travel, hospitality, restaurant, and retail sectors. In China, for example, the mass shutdowns of factories evaporated the supply of products such as apparel, auto parts and electronic components and apparel.

Dial up your empathetic self

Emotional intelligence is critical in a crisis – a good and effective leader recognises the impact uncertainty has on the people who drive the business. Resilient leaders express empathy for the upheaval’s human side, acknowledging their employees’ priorities shift towards their family health and safety. A resilient leader prioritises workers and protects their economic well-being. Effective leaders also encourage their people to adopt a calm and systematic approach to whatever happens next –

At the onset of the COVID-19 outbreak, Deloitte conducted a human capital policies and practices survey in China. And the survey revealed the following steps companies and not-for-profit organisations were considering in response:

• More than half of government and public service entities focused on addressing employees’ psychological stress.
• 90% said it was an urgent requirement to provide their employees with remote and flexible work options.
• Companies in industries facing the most significant constraints on providing flexible and remote working options—such as energy, resources, and industrials—focused on providing physical protection (i.e. cleaner and safer work environments and PPE.

Cater to your audience

Because of COVID-19, customer experience takes on a new meaning – as customer’s needs dramatically shift from what you perceived before. Your customers are reverting down Maslow’s Hierarchy of Needs to essential concerns due to COVID-19. A recent McKinsey survey of U.S. consumers found that 64% of respondents have felt depressed, anxious, or both, and 39% stated that they would be unable to pay their bills after one month of unemployment.

Are you adapting your communications and customer experience to fulfil their new needs? Show empathy towards your customers, too —they are struggling through the crisis, and simple things can differentiate you from other businesses. Leading organisations are reorienting their customer experience such as:

• UberEats asks customers if they want food left at the door rather than passed by hand.
• Airlines are waiving cancellation fees and have emailed customers to describe their enhanced plane decontamination efforts.
• Energy companies are not shutting off power for nonpayment, and in some cases, they are even reconnecting customers whose service had been turned off before the crisis.
• Restaurants have encouraged their staff to visibly use hand sanitisers.
• Burger King provides two free kids meals to Americans who make any purchase through the Burger King app.

Yet, for the sake of those same employees and customers—as well as creditors and investors— leaders must stay vigilantly focused on protecting financial performance during and through the crisis – and making hard, fact-based decisions. The adage “cash is king” is most real amidst an existential event.

The following critical steps can help you protect your business performance:

1. Centralise decision-making: uncertainty paralyses decision-makers. Allocate or create a crisis team that is capable of consistency, speed, and especially decisiveness when making decisions
2. Articulating different economic scenarios (and fast) across all markets, generally scaling scenarios from mild to moderate to severe.
3. Project the financial impact of the scenarios on profitability and especially liquidity. This includes assessing the probability of violating debt covenants and terms and determining when available cash sources should be drawn.
4. Defining the non-negotiables: Which products, services, customer segments, business lines, employee segments, and so on are the most critical to ongoing and future cash flow and should be preserved, although even those non-negotiables may be impacted if scenarios tend to the more severe.
5. Identifying the levers leadership has available (within the boundaries of the non-negotiables) to impact financial performance, such as discretionary expense reduction, hiring freezes, or temporary plant closures.
6. Determining what actions to take and agreeing on the hierarchy of levers to be pulled as the severity of scenarios unfolds.

Developing a downturn planning playbook is important to have a head start in crises. A crisis playbook should include all scenarios, projections and non-negotiables so that it is easier to be adjusted for present circumstances. However, it is important to remind that a resilient leader knows a company’s purpose should remain unchangeable. Articulate a purpose beyond profit; in a recent survey by Forbes, 79% of business leaders believe that an organisation’s purpose is central to business success, yet 68% said they do not use it in leadership decision-making processes in their organisation.

COVID-19 has left under increased pressure, and stakeholders are paying close attention to every move. Therefore it is important to make decisions that tie back to the organisation’s purpose. Purpose-driven organisations tend to do better during challenging environments because:

1.  Purpose cultivates engaged employees: Employees perform better when they feel that their work has meaning. Research shows that employees who feel that their work has meaning and has a greater sense of connection perform better during volatile times and are there to help companies recover and grow when stability returns. Companies need to centre their business on an authentic purpose.
2.  Purpose attracts loyal customers and helps grow sales: Being a purpose-driven brand is 100% beneficial for your bottom line, no doubt about it. 8 in 10 consumers say they are more loyal to purpose-driven brands – a purpose-driven brand helps sustain customer relationships even during a crisis. When a business puts the purpose first, profits generally follow; however, the results can be more elusive when profits are first.
3.  Purpose helps companies transform: When companies face hard decisions, they tend to have a sharper sense of how they should evolve when guided by their purpose. Purpose makes for a cohesive transformation.
4. Purpose always put the mission first Organisations in the middle of a crisis face a flurry of urgent issues across innumerable fronts. Resilient leaders zero in on the most pressing of these, establishing priority areas that can quickly cascade.

Six top emergency management leading practices:

1.  Centralise command– launch and sustain a crisis command centre: Leading companies established emergency response teams to assess the risks and formulate response strategies after conducting robust scenario planning, which significantly improved the epidemic response mechanism and toolkits.
2. Support talent and strategy – retain & support talent, and they will enhance strategy: After the COVID-19 outbreak, many companies began implementing flexible work and working from home arrangements. Resilient leaders saw this as an opportunity for improvement, and many companies have identified and addressed new ways of work and communication within the organisation. Furthermore, leaders quickly understood the side effect of WFH and implemented a digital employee health declaration system to track their well-being.
3. Maintain and plan your financing and ensure business continuity: Update and develop business continuity plans to understand contractual obligations, evaluate financial impacts and liquidity requirements, formulate debt restructuring plans, and optimise assets to help restore economic viability. Another core focus was understanding the economic effects across the entire value chain.
4.  Support and trust your Supply chain: invest in digital trading solutions to combat supply chain interruptions, overcome logistics and labour shortages, and get better visibility into local access limitations to ensure product supply for the domestic market. Operational agility and data quality were critical in supply chain scenario planning.
5. Stay engaged with your customers:  maintain an open and ongoing line of communication with your customers, including informing them of any emergency actions taken. This approach of working in partnership has built confidence amid the uncertainty.
6.  Invest in Digital capabilities and develop digital roads – Strengthen digital capabilities: Revisiting your current marketing and e-commerce landscape for the short, medium, and long term is crucial for your business to succeed during a crisis. The current situation has made companies realise that to increase resilience, they need to implement digital capabilities across the entire organisation, promoting “no-touch” experiences and stepping away from brick-and-mortar presence.

Apple’s bold decision-making of closing 11 retail stores in COVID-19 affected areas in the U.S. demonstrates the courage inherent in Aim for speed over elegance. Apple also demonstrated several other principles:

• Empathising with the needs and concerns of its employees, including continuing to pay hourly workers as though operations followed a regular schedule and amending its leave policy for COVID-related health issues
• Reducing further shocks to an already depleted supply chain
• Staying connected to—and overtly demonstrating concern for—its customers and local communities
• Leveraging its at-scale digital presence by keeping its online store open and running
• Continuing to engage its business ecosystem via new channels, shifting the annual Worldwide Developers Conference in June to a digital-only gathering
• #7 – Engage with your business ecosystem

Speed is key

Covid-19 has tested companies and their reaction time. The reality is that most companies do not have the infrastructure to deliver accurate information or data in real-time, which has tested their operations. And COVID-19 will continue to test companies- are you ready to accept that you’ll need to act with imperfect information? Collect as much proxy data as you can to inform your decisions, so you’re not flying blind. When the crisis is over, you will have the opportunity to conduct a thorough review to see how to improve information quality in future crises—but during this one, you will likely have to set aside that kind of analysis.

Perfect is the enemy of the good, especially during crises when prompt action is required. An effective leader understands that teams and individuals deeply embedded in a specific context are likely to be in the best position to develop creative approaches during a crisis. COVID-19 is forcing leaders into situations that were never anticipated – however, this is a great opportunity to encourage more initiative and decision rights at all levels of the organisation.

Tip: Make the objective clear, but allow more flexible local autonomy.

Case study: one coffee shop chain gave each store leadership the flexibility to reconfigure tables to maintain social distancing. This approach may have value beyond the current crisis as organisations learn to conduct business in more and more uncertain times.

Medium is the message.

Marshall McLuhan’s famous statement “the medium is the message” in the midst of a crisis is even more relevant during the COVID-19 crisis.

Many psychologists assert that most communication today lacks eye contact, voice intonation, and body language essential to building a trust-based relationship.

Tip: Body language is essential in building a trust-based relationship with your team. Instead of emails, encourage video to connect emotionally with your teams – and avoid the overwhelming feeling a busy inbox leaves.

Communication is key; as a leader, your team and stakeholders depend on your regular guidance. There is a fine balance between communicating in advance of all the facts and being late to comment. We have seen leading companies adopt a policy of shorter, more frequent communications based on what they do know and filling in details later. Incomplete or conflicting communication will slow your business’ response; your teams and stakeholders may start filling the void with misinformation and assumptions.

In a time of crisis, trust is paramount. This simple formula emphasises the key elements of trust for individuals and organisations:

Trust = Transparency + Relationship + Experience

Trust starts with transparency: telling what you know and admitting what you don’t. Trust is also a function of relationships: some level of “knowing” each other and your employees, customers, and ecosystem. And lastly, it also depends on experience: Do you reliably do what you say? In times of growing uncertainty, trust is increasingly built by demonstrating an ability to address unanticipated situations and a steady commitment to address the needs of all stakeholders in the best way possible.

This is not just about charts and numbers. It’s also important to recognise and address the emotions of all stakeholders. Narratives can be powerful ways to acknowledge the fears that naturally surface in times of crisis while at the same time framing the opportunity that can be achieved if stakeholders come together and commit to overcoming the challenges that stand in the way.

This is not just about charts and numbers. Narratives can be powerful ways to acknowledge the fears that naturally surface in times of crisis while at the same time framing the opportunity that can be achieved if stakeholders come together and commit to overcoming the challenges that stand in the way.

It’s a marathon, not a sprint

Any period of volatility can create opportunities that businesses can leverage if they are prepared. In the case of the COVID-19 outbreak, organisations that take a more assertive and longer-term approach can spark innovations that will define the next “normal.”

Harvard Business Review has assessed the corporate performance of over 4.7000 companies during the past three recessions and found that those that cut costs fastest and deepest had the lowest probability of outperforming competitors after the economy recovered. In other words, to emerge from a recession, your businesses need to strike the right balance between short- and long-term strategies by investing comprehensively in the future while selectively reducing costs to survive the recession. During the COVID-19 ……. particularly susceptible to a short-term mindset.

Plan structural changes and any lasting effects

COVID-19 is likely to accelerate fundamental and structural changes that were inevitable in any case—but are now expected to occur far faster than they would otherwise. Consider that the “digitalisation” of work—undertaken from home or elsewhere, with remote collaboration and reduced travel for physical colocation—has been evolving steadily. Today, all around the world, businesses—and their talent—are learning to communicate, collaborate, and coordinate on virtual platforms and understand the increased efficacy and efficiency such work modalities can provide. Virtual work and collaboration tools will likely create a booming new market space.

The necessity of operating differently allows businesses to understand what they can do. These structural changes will require you to alter your business strategy and planning. So ask yourself:

• How can I shift my staffing model to allow more telecommuting or remote work? And how will that shift affect our real estate portfolio?
• Can we achieve cost savings by shrinking our organisation’s physical footprint?
• What upgrades are required for video conferencing and network availability?
• Will I need more robust cybersecurity protocols?
• If I adopt a decentralised work model, what new liabilities or challenges will I have to face?
• What changes do I need to make to management, employee training and communication policies to run a more distributed workforce?

COVID-19 is forcing businesses to operate differently from what they know best. However, this can allow businesses to understand what they can do.

Tip: Test your team while they are WFH. Testing can determine if your company can meet any future requirements if the current conditions persist – then, with the appropriate data, you can consider whether you should continue doing so.

Only Market Shapers can thrive.

Shaping your current strategies can create a source of new value that can ultimately help you emerge from unanticipated crises. Those who shape their industry’s future rather than adapt to it will emerge stronger than the rest. Organisations emerging from this crisis and shifting into the “future-proofing“ stage will need to reinvent themselves, from identifying and solving new opportunities to aligning themselves with the future-shapers of their industry or even becoming the nexus of the next ecosystem. At the same time, their competitors focus on the crisis.

COVID-19 impacts have created considerable investments in new manufacturing technologies that allow businesses to shorten the time between production to consumption—creating entirely new markets to be shaped.

Predict new business models and implement them

Newly shaped markets prompt new business models – COVID-19 has tested business infrastructures, and some have crumbled. How will emerging trends, structural changes, and new markets redefine how your company and industry will be organised tomorrow?

For example, many have long realised that education was ripe for significant changes enabled by digital technologies. According to the United Nations, with over 290 million students out of school globally due to COVID-19, the demand for online offerings, curricula, and platforms will likely accelerate. Yet, some universities and faculty are just beginning to improvise remote offerings. Designing around the massive COVID-19 constraint demonstrates the real promise of potentially revolutionary changes in how we structure, locate, and operate our approaches to learning—which are likely to lead to dynamic new market-making opportunities in this area.

How will emerging trends, structural changes, and new markets redefine how your company and industry will be organised tomorrow?

As another example, consider the growth in the adoption of A.I. and robotics. 

Already playing a pivotal role in detecting and treating COVID-19, AI-equipped tools scan social media to analyse virus progression in real-time, recognising viral pneumonia in chest CT scans 45 times faster than humans with 96% accuracy, and conducting molecular synthesis and validation in days rather than months or years.

There is a real sense of urgency to stop COVID-19 from further damage. With private and public sectors partnering and investing in answers, the future health care models will change as over half is slashing the typical decade-long pharmaceutical R&D cycle, and the regulatory framework is skipped.

COVID-19 will continue to test resilient and effective leadership

COVID-19 will redefine any resilient leadership. Leaders will need to lead their organisations between having to make decisions without perfect information, often with only a few hours or days to spare. More than ever, the myriad of decisions and challenges will significantly implicate the organisation’s whole system, from employees to customers, from clients to financial partners, from suppliers to investors, and other stakeholders—as well as society.

Clarity of thinking, communications, and decision-making will be at a premium. Those CEOs who can make the best exhibit this clarity—and lead from the heart and the head—will inspire their organisations to persevere through this crisis, positioning their brand to emerge in a better place, prepared for whatever may come. Crises like these, with deep challenges to be navigated, will also lead to opportunities for learning and deepening trust with all stakeholders while equipping organisations for a step change that creates more value not just for shareholders but also for society.

Action guide for effective leadership

Launch and sustain a crisis command centre

Most organisations in the affected regions have launched some form of the crisis response unit, either as a result of a preestablished crisis response plan or on an ad hoc basis, to gain an enterprisewide understanding of the impact and coordinate their efforts across functions. Subteams have been created to manage specific workstreams such as communications, legal, finance, and operations. They operate with a clear mandate provided by executive management and have been empowered to make swift decisions in the following areas.

Such a command centre doesn’t have to be entirely defensive: It can also help break traditional orthodoxies. Airlines that are cancelling flights, for example, are making the downtime more productive by prioritising scheduled maintenance for grounded aircraft—and reallocating larger planes to space-constrained routes—enabling them to make more efficient use of resources.

Such a command centre doesn’t have to be entirely defensive: It can also help break traditional orthodoxies.

Support talent and enhance strategy: work, workforce, and  workplace

It is key to support your talent while they support your strategy. To do so:

1. Evaluate the actual work of your company and how it might be changed. Work has to be onsite and evaluate what safeguards can be implemented, such as revised cleaning protocols or personal protective equipment. Resilient leaders rapidly assess what work is mission-critical and what can be deferred or deprioritised and then help teams understand where their focus needs to be (including what work is not strategically critical). Allow your people to focus on the most vital tasks and empower teams to be creative in delivering nonessential work in ways that minimise unnecessary risk or exposure to your employees and your customers.
2. Focus on the workforce: because the most effective plans encompass employees (as well as contractors, vendors, partners, and unions) who need to be included to keep the entire workforce safe. Address the immediate COVID-19-related human needs for information, including education on COVID-19 symptoms and prevention and access to employee assistance resources. As the work itself contracts and/or expands, ensure that you have operational plans for site disruption and reactivation, including communicating to affected employees. While assessing possible changes to leave policies (such as for employees caring for affected family members), also prepare for potentially higher absenteeism, lower productivity, and even work refusal until the situation ultimately normalises post-crisis.
3. Understand that the workplace and its culture are critical: because of COVID-19, companies need to ensure the safety of working environments and prepare workplaces for containment and contamination. Suppose an employee is suspected of being infected with COVID-19. In that case, a clear process must be in place for adhering to local health care requirements for isolating and/or treating the employee at the facility.

As COVID-19 continues to change any workplace culture, as an effective leader, how you deploy your workforce, distribute work and engage your people will change. Explore this new narrative to think about how you can elevate communications and create a more effective and healthy workforce.

Plan business continuity and financing

In almost every financial crisis, preserving cash and liquidity is a top priority. Even the most financially stable can struggle when challenges impact all industries simultaneously. In the 2008–2009 recession, Companies with strong balance sheets were among the many that still experienced liquidity constraints when commercial paper markets were suddenly interrupted. In some cases, this compromised their ability to meet basic short-term obligations.

The COVID-19 crisis will be no exception – there is a long period a large number of companies now face weeks, if not months, of disrupted markets. For many industries—such as travel and hospitality—the revenue lost during this period may be permanent rather than made up later. That’s putting sudden, unanticipated pressure on working capital lines and liquidity.

Some companies may maintain adequate flexibility by making drawdowns on their revolving credit facilities. Others find that they need to approach their banks to arrange temporarily larger facilities and/or covenant resets/waivers. However, such efforts could prove unsuccessful since banks may have reached their risk tolerance limits for a single credit. Revolving credit facilities may be frozen due to covenant limits and/or cross-defaults. Security packages hastily assembled to support new funding may be insufficient due to limited collateral availability or prolonged economic distress. Or companies may be looking for a highly customised, rolling short-term facility on terms that do not naturally fit into a bank’s standard product suite.

Beyond immediate cash needs, the finance function also must respond to potential accounting and financial reporting implications—if they can even get their books closed and/or audits completed in affected areas. For instance, some corporations implementing first-ever (and quite appropriate) remote work arrangements may face unexpected tax challenges when paying employees in a different local tax jurisdiction than their main office.

Supply chain due to diligence

As the “world’s factory,” any significant disruption in China puts global supply chains at risk. The COVID-19 crisis, originating from the highly industrialised province of Wuhan, highlights the potential perils of this dependency: More than 90 per cent of Fortune 1000 companies had Tier 1 and/or Tier 2 suppliers in most-affected China provinces.

A decades-long focus on supply chain optimisation to minimise costs, reduce inventories, and drive up asset utilisation has improved many companies’ supply chain efficiency. But COVID-19 illustrates that many companies are not fully aware of the vulnerability of their supply chain relationships to global shocks when optimising for efficiency over resilience. Further, COVID-19 demonstrates that a global outbreak can have many longer-lasting impacts than a local epidemic on a supply chain, which endures foreshocks and aftershocks as hot spots evolve worldwide.

Without a comprehensive plan or playbook—and most organisations lack one for addressing a global outbreak—companies can over adjust, causing greater disruption and unnecessary expenses. For example, some companies have responded to the COVID-19 crisis by imposing across-the-board inventory increases out of fear of running short of necessary supplies. For example, a bulge in retail apparel inventory concurrent with a rapid drop in consumer spending can exacerbate cash needs. Such decisions need to thoughtfully consider the unintended consequences and shocks.

See the sidebar “Strengthening the supply chain” for important actions to consider to strengthen your global supply chain.

Strengthening your supply chain

Supply-side: For companies that produce, distribute, or source from suppliers in affected areas, steps may include:

• Enhance focus on workforce/labour planning
• Focus on Tier 1 supplier risk
• Illuminate the extended supply network
• Understand and activate alternate sources of supply
• Update inventory policy and planning parameters
• Enhance inbound materials visibility
• Prepare for plant closures
• Focus on production scheduling agility
• Evaluate alternative outbound logistics options and secure capacity
• Conduct global scenario planning

Demand-side: For companies that sell products or commodities to affected areas, steps may include:

• Understand the demand impact specific to your business
• Confirm short-term demand-supply synchronisation strategy
• Prepare for potential channel shifts
• Evaluate alternative inbound logistics options
• Enhance the ability to allocate to customers based on priority
• Open channels of communication with key customers
• Prepare for the rebound
• Conduct global scenario planning

Inside: For companies that operate or have business relationships in affected areas, steps may include:

• Educate employees on COVID-19 symptoms and prevention
• Reinforce screening protocols
• Prepare for increased absenteeism
• .Restrict nonessential travel and promote flexible working arrangements
• Align I.T. systems and support to evolving work requirements
• Prepare succession plans for key executive positions
• Focus on cash flow

Stay engaged with your customers.

You must maintain a relationship with your audience, and it is time for your company’s brand to lead. During crises, customer needs shift dramatically – from the rational to the emotional – it is your job as a leader to intercept that shift.

A study of consumer behaviour found that a business’s traditional customer segments are at risk during a downturn. Their purchasing behaviour is driven more by their emotional response to the economic volatility than by the characteristics businesses typically consider when defining their customer segments.

Particularly important is to consider how your own sales efforts will appear. Suppose you’re going to offer price cuts or marketing promotions. In that case, some might see that as an attempt to capitalise on a crisis—or worse, undermine public health efforts to encourage people to stay out of stores and other public places. Look at other benefits you can offer customers that help sustain the customer relationship. For example, some hospitality companies are deferring the expiration of loyalty points.

Digital Transformation inside and outside

With the COVID-19 lockdowns happening more often than not and the recommended “social distancing” becoming permanent, organisations had to change. Resilient companies expanded their operations into the virtual and digital sphere.

Decisions like asking their workforce to WFH pushed companies into a digital transformation. 70% of companies had a digital transformation or were working on one. However, COVID-19 tested organisations and their digital capabilities. As a resilient leader, if you are prepared to make remote work a reality, you must ensure that the organisation can support it. Also, consider the impact of WFH on your team, who are likely to feel socially isolated. Dispersing your workforce remotely comes with the potential loss of innovation as the isolation will limit in-person interaction.

The increase in online activity will have big implications on your system stability, network robustness, and data security, especially if you do business in parts of the world where telecom and systems infrastructure is lacking. The key here is to ensure your team has a system in place, ensuring smooth operation as the workplace and workforce evolve. There is also the cyber risk your organisation faces with such arrangements. Since the lockdowns, phishing scams and other cyber attacks have been rising; the fraud rate has risen by 33%. Implementing the proper cybersecurity protocols will safeguard your networks, data and team. Our article on how the COVID-19 increased identity theft cases: 7 steps to lessen your risk can help you understand all of the steps you can take to protect your business.

Maintaining customer connections virtually amid shifting behaviours also has challenges. As COVID-19 fears rose in the United States in early March, online sales increased 75% year over year, and the number of online shoppers increased too. While retailers may want to move more sales online to offset declining store traffic, they should ensure that their team has tested a scaled capability before making such a shift. Providing substandard service could damage your brand long-term than the lost sales in the short term.

Embrace your business ecosystem and future-proof your company

With new business models emerging from the crisis COVID-19 is creating, you have an opportunity to become the nexus of a brand new future-proof ecosystem. This new global and digital ecosystem will add layers of complexity and potential vulnerabilities to your business—but it can also offer opportunities that can future-proof your company. As an effective leader, consider the following questions:

• How can we use the ecosystem to improve the resilience of our organisation during COVID-19?
• How am I extending my stakeholder communication to embrace ecosystem partners that have become critical business model components?
• What additional data might my partners have to improve my operations?
• What level of communication is appropriate for the investor community—the more traditional “ecosystem”.
• As new business models emerge from the crisis, can I become the nexus of a new, emerging ecosystem built for the new “normal”?

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You suspect employee fraud. Now what?

When any type of fraud, including employee fraud, is discovered, it’s usually by surprise. That’s because most of us aren’t used to looking for criminal behaviour inside our own organisation. We trust our employees and co-workers, and we keep our focus on succeeding as a team and accomplishing our goals for the business. Nobody wants to think that someone might be subverting the rules for their own personal gain.

Unfortunately, though, fraud does happen. The statistics tell us that on average, organisations lose about 5 percent of their total revenues to fraud. If that’s not bad enough, the average fraud lasts 18 months before being discovered – if it is discovered at all (ACFE, 2020).

One of the problems is that, since we aren’t looking for fraud, we sometimes don’t want to believe it when we do encounter its red flags. Though they may be unmistakable to some, when it involves our trusted co-workers (and even our superiors) sometimes we try to rationalize or ignore those signs altogether. Accounting discrepancies are one thing, but what about the more subtle things – like behavioural red flags? The following are a few examples:

• The subject appears to be living beyond their means
• They are having financial difficulties
• They have an unusually close association with a vendor or customer
• The subject shows excessive control issues or unwillingness to share duties
• They demonstrate unusual irritability, suspiciousness, or defensiveness
• The subject has what can be described as a “wheeler-dealer” attitude involving shrewd or unscrupulous behaviour
• They have recent divorce or family problems.

Now, these are just warning signs. None of them mean that fraud is definitely taking place. But it’s worth noting that, according to the ACFE, “at least one of these seven red flags had been identified before the perpetrator was caught in 76% of all cases.”

When such behaviours are put in the context of real discrepancies, such as accounting problems, missing cash or inventory, or other issues, a picture of fraud can begin to take shape. While most fraud is discovered by accident, having employees who are trained to recognise red flags is no accident and makes your organisation better protected in the long run.

So, now you’ve discovered fraud in your organisation. What happens next?

1. Report it

Depending on your company’s anti-fraud policy, you should follow the proper reporting channels. Many organisations have an anonymous reporting system, such as a hotline or online module, through which they can report suspected fraud without fear of retaliation. Such a system is highly recommended, as it directly results in more fraud tips and helps you uncover bad behaviour sooner, before it’s done the most damage.

2. Begin an investigation

Organisations that don’t have their own anti-fraud professionals on staff should engage an outside firm that specialises in financial investigations whenever fraud is suspected. These experts will review your fraud tip and lead your organisation through the next steps.

3. Gather evidence

Only seasoned experts should engage in an investigation because improper evidence collection can harm the potential to bring a case to court, should it rise to that level. Also, professional fraud investigators have an understanding of privacy laws and know what is and isn’t admissible in terms of gathering evidence in the workplace.

4. Interview witnesses

Part of the evidence-gathering phase, witnesses should be interviewed to draw a clear picture of what has taken place. They should be interviewed individually by anti-fraud professionals, who know how to elicit the information they need to uncover the truth.

5. Contact law enforcement

As the investigation proceeds, if fraud appears to be a proven concern, the employee should be terminated from employment and law enforcement should be informed. Without prosecution, the fraudster will just move on to their next victim.

6. Review and update your anti-fraud controls

How did this fraud happen? Were anti-fraud measures too weak, or were they not properly followed? Now is the time to evaluate risk management and control systems to learn from this case, and prevent the next fraud. Due diligence experts should be engaged to provide an objective, thorough examination of your control systems and make recommendations that will improve your level of protection.

CRI Group has experts who have conducted fraud investigations all around the world, for organisations of all sizes and industries. Our investigators work on-site at your company bringing a boots-on-the-ground approach to uncovering all the facts of the case. When you’ve uncovered fraud, that’s the time to let the experts take over. You owe it to yourself and the future of your business to make sure every investigation is done professionally and effectively. Contact CRI Group to learn more about our fraud investigations today. Get a FREE QUOTE

CRI Group has safeguarded businesses from any risks, providing investigations (i.e. insurance fraud), employee background screening, investigative due diligence, business intelligence,  third-party risk management, forensic accounting, compliance and other professional investigative research services. In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. Contact ABAC® for more on ISO Certification and training.

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Managing Third-Party Risks: A Checklist

THIRD-PARTY RISK MANAGEMENT CHECKLIST

Third-party risk management checklist. Fraud doesn’t take a break in times of crisis – in fact, that’s often when it thrives. And the same is true for supplier fraud. Unethical business practices by third-party partners can directly impact your organization in all sorts of ways. This type of fraud can cause financial, logistical, and reputational harm.

Locked in the grips of the COVID-19 pandemic, New York City found itself desperately in need of medical supplies. In particular, the city hit hard by the pandemic required millions of 3M-brand N95 respirators, the type that keeps health care workers, police, paramedics and others safe. A supplier emerged to fill this need potentially.

Unfortunately, he had a scheme to defraud the city of $45 million through price-gouging and fraudulently posing as a 3M- dealer. The formerly used car dealer in New Jersey, the fraudster now faces wire fraud and wire fraud conspiracy charges in a three-count criminal complaint unsealed in the U.S. District Court in Manhattan (New York Times, 2020). Managing Third-Party Risks

The case is an unfortunate reminder of what type of fraud and corruption lurks in supply chains. While a crisis presents new vulnerabilities – often, safeguards are bypassed for urgency – companies must be always on guard for third-party fraud. Due diligence isn’t just a corporate buzzword, nor is it a concept to keep compliance officers happy. It must be an integral part of every organization’s core business model. Every organization can do the following key third-party due diligence measures to stay better protected from supplier or contractor fraud.

THIRD-PARTY RISK MANAGEMENT CHECKLIST EVERY ORGANISATION COULD USE:

1. Identify vulnerabilities

Before evaluating its third-party partners, an organization should look inward and measure its own risk management tools. These include the following:

• Audit and supervision functions
• Business continuity plans, supply chain alternatives (very critical would considering third-party contracts)
• Jurisdictional considerations
• Data and IP protection
• Whistleblower policies

2. Conduct due diligence

The organization should engage a risk management process on all current and potential suppliers and contractors. For each third party, the organisation should evaluate the following:

• Business and operations
• Financial condition and reputation
• Experience, culture, vision and business style
• References and government records (including any legal action, bankruptcies, structure changes)
• Background checks (including ownership and key personnel)
• Insurance and certifications

3. Maintain management oversight

Due diligence is only worthwhile if appropriate action is taken in response to its findings. Once third-party partnerships have been evaluated and approved, the organization should continue to manage, monitor and maintain these relationships. Risk management is not a one-time process. It should be scheduled regularly (yearly at minimum) to ensure the proper standards are maintained for the organization. Not every company or government organization is ordering emergency supplies due to COVID-19 or other crises. With proper third-party due diligence, third-party due diligence can protect organizations year-round from the risk of any of the following serious pitfalls:

• Merging with an international business embroiled in behind-the-scenes legal battles.
• Getting caught up in making procurement decisions involving the inappropriate influence of government officials who were slated to receive kickbacks.
• Partnering with organizations that are potential credit risks, have claimed bankruptcy, have dissolved stated companies or are faced with debtor filing.
• Awarding work to an overseas contractor with absolutely no prior experience
• Affiliating with a contracting company owned by a politician with significant influence on future awards

It is recommended and necessary for many organizations to have a team of professionals guide you through implementing a comprehensive program for third-party risk management. That’s where CRI® Group comes in. We have one of the largest, most experienced and best-trained integrity due to diligence teams globally. With multi-lingual teams that have conducted assignments on thousands of subjects in over 80 countries, CRI® Group’s due diligence experts are committed to maintaining and constantly evolving our global network.

Managing risk effectively is essential to ensure businesses succeed and thrive in an environment of constant uncertainty. This playbook covers everything you need to know about ISO 31000:2018; here’s a quick rundown of the playbook structure:

• What is ISO 31000? Why is this Standard a good idea?
• ISO 31000 framework, why was it revised? And What are the main differences?
• Key Clauses of 31000:2018 and Who is the standard for?
• The process and the link between 31000:20180 and other standards

Getting Started with ISO 31000 Risk Management?

DOWNLOAD ISO 31000 PLAYBOOK NOW

3PRM-Certified™ a third-party compliance verification and certification program

As the risk for data breaches and supply chain disruption continues to rise with COVID-19, so does the need for effective third-party risk management (TPRM) programs. Whether you’re a TPRM professional looking for a certification to advance your skillset, or the leader of your organization considering how to better equip your team with the best knowledge and skills, the 3PRM-Certified™ program is an all-in solution. Our 3PRM™ service is flexible, and we tailor our scope to address an organization’s specific concerns and risk areas. CRI® Group’s exclusive 3PRM-Certified™ solution provides the very best in third-party risk management. Our 3PRM-Certified™ program provides a proactive approach to mitigating risks from third-party affiliations, protecting the organization from liability, brand damage and harm to the business. The 3PRM-Certified™ program includes a focus on the following:

• Providing third-party risk assessments
• Meeting contracting requirements
• Conducting due diligence
• Identifying potential fraud risks
• Providing management oversight

Utilizing a network of trained professionals positioned across five continents, CRI® Group’s 3PRM services utilize one of the largest multi-national fraud investigation teams the industry has to offer. The 3PRM-Certified™ program is especially critical when your business is performing pre-merger and acquisition research and pre-IPO due diligence, engages new clients, employs, contracts or retains foreign business partners and requires a consistent and audit-worthy AML and anti-corruption compliance program.

This TPRM Strategy program will help organizations establish the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. Third-party relationships are critical in business today and include partnerships with suppliers, distributors, consultants, agents and other contractors. While such affiliations are essential to the success of your organization, an organization cannot overestimate the consequences of inadequate due diligence.

VIEW 3PRM^TM BROCHURE

Let’s Talk!

Get ahead of any potential problems down the road with suppliers, contractors, and other third-party partners. Our extensive solutions include due diligence, employee pre- and post-background screening, business intelligence and compliance, facilitating any decision-making across your business no matter what area or department. Contact CRI® Group today and learn more about our third-party due diligence and risk management solutions. If you have any further questions or interest in implementing compliance solutions, please contact us.

GET A FREE QUOTE NOW

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organizations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

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Can ISO 37001:2016 prevent bribery?

Since its launch in 2016, ISO 37001 Anti-Bribery Management Systems standard has had its supporters and critics. Some regulatory bodies and compliance communities initially expressed concern regarding the lack of a body of evidence supporting the effectiveness of ISO 37001:2016 from certain standpoints. Critics asserted that the new standard failed to address broad compliance concerns, and questioned whether ISO 37001:2016 certification alone can prevent prosecution. These observations should certainly be weighed and considered, as any new compliance standard must be properly evaluated on its merits. In the case of ISO 37001, however, the critics have made some misjudgments in regards to the key factors they feel are in question with the standard. Can ISO 37001:2016 prevent bribery?

One of the most important things to remember is that a standard like 37001 and all of its measures require a commitment and implementation by the organisation adopting them. ISO 37001 is a standard, administered by a certified body but ultimately implemented by employees of the organisation itself. The purpose of ISO 37001 standard is to provide a framework against which an organisation’s anti-bribery management can be assessed and certified, rather than a foolproof blueprint to prevent bribery.

The story behind ISO 37001:2016

First, some background: The International Organization for Standardization, or ISO, is the international standard-setting body composed of representatives from various national standards organisations. Founded on 23 Feb. 1947, ISO promotes worldwide proprietary, industrial, and commercial standards. Responding to an international need, ISO issued the 37001:2016 Anti-Bribery Management System standard to help businesses, nonprofits and governmental agencies reduce their risk of bribery and corruption by establishing, implementing, maintaining and improving an anti-bribery management system.

The ISO 37001 standard requirement, which references to ISO 19600 – Compliance Management System, specifies mandatory requirements for organisations when establishing/updating their anti-bribery management programs in a manner that is proportionate to the potential bribery risk. The reference to these requirements is referred to as “appropriate” and “reasonable”, hence directing organisations to undertake a subjective, diligent and rigorous review of current compliance framework, which will make ISO 37001 effective for them. According to Deloitte & Touche LLP, “[in ISO 37001:2016] it’s the substance, not the form, of a compliance program that determines its effectiveness”.

Anti-corruption versus broad compliance issues

Some of the concerns regarding the effectiveness of ISO 37001 are focused on whether it addresses broad compliance issues, like inequality, harassment, various types of fraud (outside of bribery and corruption), or similar offences. Seeing that it generally does not, as its focus is on anti-bribery and anti-corruption compliance, some take the view that ISO 37001 has adopted a simplistic approach. The scope of ISO 37001 addresses “establishing, implementing, maintaining, reviewing, and improving an anti-bribery management system,” whether as a stand-alone initiative or part of a broader anti-corruption. Therefore, implementing ISO 37001 standard requirements should be viewed as a way of enhancing, rather than replacing, an organisation’s existing anti-corruption compliance programs.

ISO 37001 is effective step-by-step guidance for those organisations which lack an anti-corruption framework and enables them to implement a compliance program without investing significant time in identifying the regulatory and non-regulatory requirements. In fact, ISO 37001 has incorporated Federal Sentencing Guidelines, U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Resource Guide to the U.S. Foreign Corrupt Practices Act, the U.K. Ministry of Justice Bribery Act 2010 Guidance, and OECD’s Good Practice Guidance on Internal Controls, Ethics and Compliance. Former U.S. Deputy Attorney General Rod Rosenstein highlighted three hallmarks of a policy-effective compliance program, which are concurrent with ISO 37001 requirements and include: fostering a culture of compliance; dedicating sufficient resources to compliance activities; and ensuring that experienced compliance personnel has appropriate access to the board.

Prosecution of offences

Lastly, there is a widely held belief that obtaining ISO 37001 certification is an effective tool to avoid prosecution for bribery. These misconceptions have not been viewed favourably insofar as to Ms. Hui Chen, U.S. DOJ’s former compliance counsel, stating “Dan Kahn, the Chief of the FCPA Unit in the Fraud Section of DOJ’s Criminal Division, has been very consistent: prosecutors will not outsource their responsibilities”. Rightly so. ISO 37001 certification does not act as insurance to corporate liability for bribery, neither does it refute the need to perform due diligence, and it should be considered and implemented as per company’s risk profile. In practicality, implementing ISO 37001 can demonstrate to enforcement agencies and regulators that the organisation has taken reasonable steps to establish a compliance program to mitigate bribery risks, however, ISO 37001 certification will mitigate the consequences, if not a shield, an organisation from investigation or prosecution.

ISO 37001:2016 embraced by organisations and governments

It is important to note that organisations and governments alike are embracing ISO 37001 as the standard for prevention and detection. One example of this is in Malaysia, where the ISO 37001 standard was adopted across the government under Prime Minister Tun Dr Mahathir Mohamad. The new system has been received positively in both the public and private sectors, and Malaysia’s former anti-graft chief said “the people’s perception on the government’s seriousness to fight corruption had increased to 70.8 per cent last year from 59.8 per cent in 2016. He said that Malaysia has also shown improvement in its performance indicators in several important international studies and indexes” (New Straits Times, 2019). True to form, various heads of government in the country are following the directive. Defence Minister Mohamed Sabu recently “cautioned his officers to adhere to the Anti-Bribery Management System, which had attained the International Standards Organisation’s ISO 37001: 2016 certification” (New Straits Times, 2019).

Malaysia is not alone. In Peru, Singapore, and China (Shenzhen Institute of Standards and Technology [SIST]), the national standard bodies have adopted and localised the ISO 37001 standard. In Italy, the ISO 37001 accreditation scheme has been developed by Accredia; whereas in the UK, United Kingdom Accreditation Service (UKAS) has undertaken an ISO 37001 pilot program to develop an accreditation scheme. In the United Arab Emirates, Emirates International Accreditation Centre (EIAC) is undertaking the ISO 37001 accreditation scheme development with CRI® Group’s ABAC® Center of Excellence. ABAC® is an initiative launched by CRI® Group and offers ISO 37001 certification services. Hence, amid these positive developments, the outlook for ISO 37001 looks promising. ISO 37001 is not a “silver bullet” to foolproof an organisation from bribery or corruption, or avoid prosecution should those offences occur. It was never designed to be. Instead, it is a framework to implement the necessary controls and systems at the organisation level – across all levels – so as to be better equipped to prevent bribery and corruption moving forward.

CRI® Group has experts who have conducted fraud investigations all around the world, for organisations of all sizes and industries. Our investigators work on-site at your company bringing a boots-on-the-ground approach to uncovering all the facts of the case. When you’ve uncovered fraud, that’s the time to let the experts take over. You owe it to yourself and the future of your business to make sure every investigation is done professionally and effectively. Contact CRI® Group to learn more about our fraud investigations today. Get a FREE QUOTE

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

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1 in 3 Furloughed UK Employees Pressured to Work

The COVID-19 pandemic has been a major crisis for businesses and employees around the world. To make matters worse, some unscrupulous employers in the UK have abused the Coronavirus Job Retention Scheme by engaging in furlough fraud. They do this by accepting taxpayer money designed to help them pay salaries for furloughed workers, who are essentially “deactivated” to due to loss of business and quarantine – yet they pressure them to work (or they accept furlough benefits without the employees’ knowledge).

The system is designed to keep companies from laying off employees during such a time of crisis. Unfortunately, a crisis can also present the opportunity to commit fraud. In this case, pressuring employees to work despite being furloughed is an abuse of the system and a violation of the law. Employers who do this are gaming the system and taking advantage of employee labour, with taxpayers footing up to 80 percent of the bill (their salary).

How big is the problem? According to a recent study, more than one in three employees on furlough in the UK are currently under pressure to continue working while on furlough (Express UK, 2020). This shocking statistic has demonstrated that the issue of abuse in the furlough system is not an isolated affair, but appears to be widespread. So much so that HM Revenues and Customs is actually offering a 30-day amnesty period for employers to “admit to deliberate non-compliance of furloughing rules” (Yahoo UK, 2020). More than 1,900 calls have been logged to the furlough fraud hotline, and companies face penalties with new legislation on the way to punish violations.

What does furlough fraud look like? Here are some of the ways that employers are abusing the system.

1. Furloughed employees are pressured to work

A survey showed that 27 percent of furloughed employees were asked to send and respond to emails, and 17 percent were asked to make phone calls. Furlough workers by law are not expected to be actively engaging in any work for the employer while furloughed.

2. They are asked to come to the workplace

Rather than being asked to work from home (which is still against the rules), 12 percent of furloughed employees report being pressured to physically attend their workplace.

3. Employees are encouraged to “volunteer”

A reported 11 percent of furloughed employees are being pressured to continuing working for their employer as a “volunteer,” which is against the law.

4. Some employee don’t even know they are furloughed

In certain cases, employers have claimed furlough on their employees’ behalf, without their knowledge, while they continue working.

In their efforts to eradicate corruption, Parliament is pushing through new draft legislation that is expected to become law in July as part of the Finance Bill 2020. Dawn Register, partner in tax dispute resolution at BDO, told Personnel Today: “It is clear that HMRC is now gearing up to tackle incorrect and fraudulent claims for Covid-19 support payments. Latest government statistics show the eye-watering numbers paid out and why HMRC resources will focus on this potential new area of fraud” (Personnel Today, 2020).

The problem of furlough fraud illustrates the danger at companies that don’t adhere to a strict ethical code of conduct. By contrast, a proper tone at the top that helps discourage fraud and corruption would make it just as difficult and unacceptable to flout furlough laws as it would be to, say, engage in bribery, or cook its books. Unfortunately, many entities in the UK will likely learn the hard way when investigations and penalties bring them into compliance at a high cost. Legislators have signalled that both criminal and civil penalties will be on the table for those companies found to be abusing the system.

At CRI® Group, our experts are focused on anti-corruption methods and help implement proper anti-fraud processes that prevent problems like furlough fraud. Our due diligence processes can also detect when such fraudulent acts are being undertaken without the knowledge of ownership or directors. Let us show you ways to detect and prevent fraud at every level, and build a corporate culture that’s based on compliance and ethics.

About us…

Based in London, CRI® Group works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.

In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC® for more on ISO Certification and training.

MEET THE CEO

Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due to diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center – QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguard businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom.

Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.

CONTACT INFORMATION

Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI® Group Chief Executive Officer

37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom

t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com

Filed under: Automotive, Aviation, COVID-19 Insights, Due Diligence, Finance & Professional services Industry, Insurance, IT & Telecommunications, Oil, Gas & Energy, Property, Resources by admin
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Brexit poses bribery challenges but ISO 37001 provides solutions

While the United Kingdom has positioned itself as a leader in the fight against fraud and corruption, the shifting economic conditions surrounding Brexit have raised uncertainty and vulnerability. As some organisations are forced to forge new trade deals outside of already established European Union (EU) relationships, some experts warn that there will be more exposure to corrupt markets. This new wrinkle comes nine years after passage of the Bribery Act 2010, which marked a major salvo in the war against bribery and corruption. The Bribery Act enhanced existing British law against corruption and placed a new level of responsibility squarely at the feet of organisations. It requires organisations to demonstrate anti-bribery procedures and controls, while also providing strict penalties for breaches of anti-bribery laws. The takeaway for UK companies is that they need to take action now. With Brexit posing challenges through new, untested trade deals in various markets, organisations need ISO 37001 – Anti-Bribery Management Systems standard as a comprehensive approach to mitigating risk. ISO 37001 include adopting an anti-bribery policy, including anti-bribery compliance, training, risk assessments and due diligence on projects and business associates. It also calls for implementing financial and commercial controls, and instituting reporting and investigation procedures.

The Persistence of Bribery and Corruption

Worldwide, bribery and corruption are still massive problems. Global anti-fraud watchdog Transparency International states that “only 11 major exporting countries – accounting for about a third of world exports – have active or moderate law enforcement against companies bribing abroad in order to gain mining rights, contracts for major construction projects, purchases of planes and other deals”. Great Britain is certainly one of those countries actively enforcing against bribery, and the UK Bribery Act placed it within the leading edge of the fight against bribery and corruption. Even still, Great Britain fell three places in Transparency International’s 2018 Corruption Perceptions Index (released in 2019). The country slipped from 8^th place to 11^th. The drop is seen by some as an embarrassment for a government that takes a hard line against corruption, and faces new challenges posed by a post-Brexit future.

Rolls-Royce Agrees to Massive Fines

Recent high-profile bribery and corruption scandals demonstrate how pervasive the problem is. Among them, a scandal involving British engineering giant Rolls-Royce led to the corporation agreeing to pay £671m to settle corruption cases with UK and U.S. authorities (£497m plus costs earmarked for the UK Serious Fraud Office, which conducted its biggest ever investigation into the firm). The SFO found conspiracy to corrupt or failure to prevent bribery by Rolls-Royce in China, India, Russia, Thailand, Malaysia, and other markets. The firm apologised “unreservedly” for the cases spanning nearly 25 years.

The wrongdoing involved Rolls-Royce’s “intermediaries”, which are local companies that handle sales, distribution and maintenance in countries where the British firm does not have enough people on the ground. Thirty-eight employees have faced disciplinary proceedings. Eleven left the firm during the disciplinary process. Six were dismissed. Rolls-Royce has also reviewed 250 intermediary relationships across the company – 88 have now been suspended.

Recently, the Serious Fraud Office says it ended its investigation but only after Rolls-Royce entered the deferred prosecution agreement and accepted responsibility “for corrupt conduct spanning three decades, seven jurisdictions and three businesses, for which it paid a fine of £497.25m”, according to SFO director Lisa Osofsky.

Cadbury Limited Pays for FCPA Violations

In another recent case, British confectionary company Cadbury Limited and its owner, Mondel?z International, Inc., agreed to pay $13 million to settle charges of violating the internal controls and books-and-records provisions of the FCPA. According to the order from the U.S. Securities and Exchange Commission (SEC), the FCPA violations arose from payments their subsidiary in India made to a consultant to obtain government licenses and approvals for a chocolate factory in Baddi, India.

An SEC investigation found that in February 2010, Mondel?z, formerly known as Kraft Foods, Inc., acquired Cadbury and its subsidiaries, including Cadbury India Limited, which manufactures and sells chocolate products in India. Cadbury India retained and made payments to an agent to interact with Indian government officials to obtain licenses and approvals for a chocolate factory in Baddi, India. Cadbury India failed to conduct appropriate due diligence on, and monitor the activities of, the agent.

From February 2010 to July 2010, the agent submitted five invoices to Cadbury India for, among other things, preparing license applications. Cadbury India employees at Baddi, not the agent, prepared these license applications. Cadbury India paid the agent a total of $90,666 (after withholding tax) upon receipt of the invoices. After receiving each payment, the agent withdrew from its bank account most of the funds in cash. During this time period, Cadbury India obtained some of the licenses and approvals. Without admitting or denying the findings, Cadbury and Mondel?z agreed to a cease-and-desist order and payment of a $13 million civil penalty.

The Bribery Act 2010 and UK Anti-Corruption Strategy 2017-2022

Passage of the Bribery Act 2010 in the UK marked a major milestone in the effort to prevent, detect, and prosecute bribery and corruption. Building off of existing British law and other international legislation like the U.S. Foreign Corrupt Practices Act (FCPA), the Bribery Act 2010 created a new offence which can be committed by commercial organisations that fail to prevent persons associated with them from bribing another person on their behalf. In turn, an organisation that can demonstrate having adequate procedures in place to prevent persons associated with it from committing bribery have a defence to the section 7 offence. In 2018, eight years after passage of the UK Bribery Act, the total number of SFO investigations was “believed to be in region of 70-75,” with “dozens” of bribery and corruption cases in the investigative pipeline.

In 2017, the HM Government (formerly Her Majesty’s Government) released its first UK Anti-Corruption Strategy 2017-2022 to provide a framework to guide government policy and action against corruption. The strategy aims to reduce threats to national security, protect the economy and foster business opportunities (especially for British businesses) and build public trust and confidence. It also sets out six clear priorities for the British Parliament: (1) reduce the insider threat in high-risk domestic sectors such as borders and ports; (2) strengthen the integrity of the UK as an international financial centre; (3) promote integrity across the public and private sectors; (4) reduce corruption in public procurement and grants; (5) improve the business environment globally; (6) work with other countries to combat corruption. The strategy’s emphasis on transparency, risk mitigation and compliance should serve as a strong indication that organisations are expected to be held to a higher standard if they are based or do business in the UK.

This is why it is of such critical importance that organisations doing business from the UK, or through/across its borders, have credentialed and tested processes like the ISO 37001 Anti-Bribery Management System Standard in place. Switzerland-based International Organization for Standardization issued the 37001 Anti-Bribery Management System Standard in 2016 to help organisations worldwide increase and measure their efforts against bribery and corruption. The standard will be discussed in depth later in this article.

Brexit and the Potential for Increased Bribery

With the UK leaving the European Union, the debate and protests have mostly been political in nature. A major concern, however, that is only recently being discussed is the potential business impact regarding bribery and corruption. In particular, the UK’s National Crime Agency (NCA) has warned that the UK’s exit from the EU will impact the prevalence of bribery and corruption over the next five years, as UK companies potentially come into greater contact with corrupt markets. In addition, there is a report so secret that it has not been made public, according to an article in the Independent that quotes NCA Director-general Lynne Owens as saying that “We produce an ‘official sensitive’ and ‘top secret’ report that would go into the detail of where and what we are concerned about”. For watchdogs on bribery and corruption, such a statement is ominous, at best.

It’s worth noting that some Brexiters see the departure from the EU as an opportunity to cut red tape, which could further the regulation problem. Brexit could prompt the UK to strike trade deals with countries that have a heightened corruption risk. To embrace a reduction of “red tape” in favour of lax controls, however, would be a monumental mistake – with the Bribery Act 2010 still in full force, along with SEC enforcement of FCPA provisions. In fact, having anti-bribery standard implemented will now be more important than ever, as the SFO and other enforcement bodies will likely be scrutinising new trade deals more than ever in a new post-Brexit landscape.

ISO 37001 Anti-Bribery Management Standard

It is in this environment that ISO 37001 ABMS becomes a critical centrepiece for any organisation’s ABMS systems. Accredited providers of ISO 37001 such as ABAC (Anti-Bribery and Anti-Corruption) Center of Excellence, a global network of certified ethics and compliance professionals, qualified auditors, financial and corporate investigators, certified fraud examiners, forensic analysts and accountants, can be used as a tool for organisations to prevent bribery and corruption. ABAC Certification is an accredited provider of ISO 37001 ABMS Certification and Training for organisations of all types and industries.

The ISO 37001 standard specifies requirements and provides guidance for establishing, implementing, maintaining, reviewing and improving an anti-bribery management system. The system can be stand-alone or can be integrated into an overall management system. ISO 37001 addresses the following in relation to the organisation’s activities:

• Bribery in the public, private and not-for-profit sectors
• Bribery by the organisation
• Bribery by the organisation’s personnel acting on the organisation’s behalf or for its benefit
• Bribery by the organisation’s business associates acting on the organisation’s behalf or for its benefit
• Bribery of the organisation
• Bribery of the organisation’s personnel in relation to the organisation’s activities
• Bribery of the organisation’s business associates in relation to the organisation’s activities
• Direct and indirect bribery (e.g. a bribe offered or accepted through or by a third party)

When administered by an accredited provider of ISO ABMS certification and training, the protocol can:

• Help an organisation create new and better business partnerships with entities that recognise ISO 37001 certified status, including supply chain manufacturing, joint ventures, pending acquisitions and co-marketing alliances
• Potentially reduce corporate insurance premiums
• Provide customers, stakeholders, employees and partners with confidence in the entity’s business operations and ethics
• Provide a competitive edge over non-certified organisations the organisation’s industry or niche
• Provide acceptable evidence to prosecutors or courts that the organisation has taken reasonable steps to prevent bribery and corruption

The ISO 37001 process helps companies and government organisations reduce the risk of bribery by establishing, implementing, maintaining and enhancing internal anti-bribery and anti-corruption systems. ISO ABMS certification is a mitigating piece of evidence to regulators or even prosecutors and the courts that the entity has taken meaningful steps in its efforts to prevent bribery and corruption.

Conclusion

With the UK moving from the EU to a post-Brexit world, the time is now for organisations to protect their investments, their reputations and their business. The Bribery Act 2010 puts an emphasis on proactive prevention and compliance. The SFO and other enforcement bodies will almost certainly respond to guidance that warns of a post-Brexit potential for increased bribery and corruption. The result will be increased scrutiny and a likely no-tolerance approach for breaches. As such, UK corporations and their overseas partners should stand ready to demonstrate their implementation of internal processes, policies and controls to prevent and detect bribery and corruption and remain in compliance.

The ISO 37001 ABMS standard is established, tried and tested program that addresses those issues head-on through a comprehensive program of training and certification. The training process is tailored to the organisation, while still following the developed curriculum and documented best practices. Certification requires demonstrating that processes have been implemented effectively, with follow-up evaluations. The shift to a post-Brexit economy is the perfect opportunity to implement ISO 37001 standards – no reputable board of directors or governors should question the timing and importance of taking this step. It’s a matter of safeguarding the organisation, its reputation, and its future.

Let’s Talk!

If you have any further questions or interest in implementing compliance solutions, please contact us.

CRI Group has safeguarded businesses from any risks, providing investigations (i.e. insurance fraud), employee background screening, investigative due diligence, business intelligence,  third-party risk management, forensic accounting, compliance and other professional investigative research services. In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. Contact ABAC® for more on ISO Certification and training.[/vc_column_text][accordion_father caption_url=””][accordion_son title=”Meet our CEO” clr=”#ffffff” bgclr=”#1e73be”]ABOUT THE AUTHOR

Zafar I. Anjum is Group Chief Executive Officer of CRI Group, a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organizations. Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, USA, and the United Kingdom.[/accordion_son][accordion_son title=”Sources & Credits” clr=”#ffffff” bgclr=”#1e73be”]

1. “Exporting Corruption”, Transparency International, 2018, < https://www.transparency.org/news/feature/exporting-corruption-2018> (accessed 18 Aug. 2019)
2. “Corruption Perceptions Index 2018”, Transparency International, 2019, < https://www.transparency.org/cpi2018> (accessed 18 Aug. 2019)

3. Caroline Binham, “UK drops out of top 10 in global anti-corruption rankings”, Financial Times, 28 Jan. 2019, < https://www.ft.com/content/8d1a2474-224e-11e9-b329-c7e6ceb5ffdf> (accessed 17 Aug. 2019)

4. Holly Watt, David Pegg, Rob Evans, “Rolls-Royce apologises in court after settling bribery case”, The Guardian, 17 Jan. 2017 < https://www.theguardian.com/business/2017/jan/17/rolls-royce-apologises-bribery-671m-uk-us-brazil > (accessed 18 Aug. 2019)

5. “Rolls-Royce apologises after £671m bribery settlement”, BBC News, 18 Jan. 2017, < https://www.bbc.co.uk/news/business-38644114 > (accessed 30 Aug. 2019)

6. “SFO drops investigations into Rolls-Royce and GSK”, BBC News, 22 Feb. 2019, < https://www.bbc.com/news/business-47330580 > (accessed 18 Aug. 2019)

7. Richard L. Cassin, “2017 FCPA Enforcement Index”, The FCPA Blog, 2 Jan. 2018, < https://www.fcpablog.com/blog/2018/1/2/2017-fcpa-enforcement-index.html > (accessed 19 Aug. 2019)

8. “ADMINISTRATIVE PROCEEDING File No. 3-17759”, SEC.GOV, < https://www.sec.gov/litigation/admin/2017/34-79753-s.pdf > (accessed 19 Aug. 2019)

9. “Bribery Act 2010 guidance”, GOV.UK, 11 Feb. 2012, < https://www.gov.uk/government/publications/bribery-act-2010-guidance > (accessed 18 Aug. 2019)

10. Lizzie Dearden, “Brexit could push UK companies into ‘greater contact with corrupt markets’ if EU trade deals lost”, The Independent, 14 May 2019, < https://www.independent.co.uk/news/uk/politics/brexit-uk-business-corrupt-markets-trade-deal-a8914016.html > (accessed 18 Aug. 2019)

11. Caroline Binham, “UK drops out of top 10 in global anti-corruption rankings”, Financial Times, 28 Jan. 2019, < https://www.ft.com/content/8d1a2474-224e-11e9-b329-c7e6ceb5ffdf> (accessed 17 Aug. 2019)

12. “ISO 37001:2016 ANTI-BRIBERY MANAGEMENT SYSTEMS — REQUIREMENTS WITH GUIDANCE FOR USE”, www.ISO.org, < https://www.iso.org/standard/65034.html > (accessed 5 Aug. 2019)

[/accordion_son][accordion_son title=”Sources & Credits” clr=”#ffffff” bgclr=”#1e73be”]

1. “Exporting Corruption”, Transparency International, 2018, < https://www.transparency.org/news/feature/exporting-corruption-2018> (accessed 18 Aug. 2019)
2. “Corruption Perceptions Index 2018”, Transparency International, 2019, < https://www.transparency.org/cpi2018> (accessed 18 Aug. 2019)

3. Caroline Binham, “UK drops out of top 10 in global anti-corruption rankings”, Financial Times, 28 Jan. 2019, < https://www.ft.com/content/8d1a2474-224e-11e9-b329-c7e6ceb5ffdf> (accessed 17 Aug. 2019)

4. Holly Watt, David Pegg, Rob Evans, “Rolls-Royce apologises in court after settling bribery case”, The Guardian, 17 Jan. 2017 < https://www.theguardian.com/business/2017/jan/17/rolls-royce-apologises-bribery-671m-uk-us-brazil > (accessed 18 Aug. 2019)

5. “Rolls-Royce apologises after £671m bribery settlement”, BBC News, 18 Jan. 2017, < https://www.bbc.co.uk/news/business-38644114 > (accessed 30 Aug. 2019)

6. “SFO drops investigations into Rolls-Royce and GSK”, BBC News, 22 Feb. 2019, < https://www.bbc.com/news/business-47330580 > (accessed 18 Aug. 2019)

7. Richard L. Cassin, “2017 FCPA Enforcement Index”, The FCPA Blog, 2 Jan. 2018, < https://www.fcpablog.com/blog/2018/1/2/2017-fcpa-enforcement-index.html > (accessed 19 Aug. 2019)

8. “ADMINISTRATIVE PROCEEDING File No. 3-17759”, SEC.GOV, < https://www.sec.gov/litigation/admin/2017/34-79753-s.pdf > (accessed 19 Aug. 2019)

9. “Bribery Act 2010 guidance”, GOV.UK, 11 Feb. 2012, < https://www.gov.uk/government/publications/bribery-act-2010-guidance > (accessed 18 Aug. 2019)

10. Lizzie Dearden, “Brexit could push UK companies into ‘greater contact with corrupt markets’ if EU trade deals lost”, The Independent, 14 May 2019, < https://www.independent.co.uk/news/uk/politics/brexit-uk-business-corrupt-markets-trade-deal-a8914016.html > (accessed 18 Aug. 2019)

11. Caroline Binham, “UK drops out of top 10 in global anti-corruption rankings”, Financial Times, 28 Jan. 2019, < https://www.ft.com/content/8d1a2474-224e-11e9-b329-c7e6ceb5ffdf> (accessed 17 Aug. 2019)

12. “ISO 37001:2016 ANTI-BRIBERY MANAGEMENT SYSTEMS — REQUIREMENTS WITH GUIDANCE FOR USE”, www.ISO.org, < https://www.iso.org/standard/65034.html > (accessed 5 Aug. 2019)

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Filed under: Anti-Bribery Anti-Corruption Solution, Compliance Solution, ISO 37001, Resources by admin
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Your company’s security begins at the hiring process

Your company’s security begins at the hiring process

It’s an exciting time for a company when business is growing and there is a need add more employees and start a hiring process. One organisation that was in such a position sought to make sure they were being diligent while hiring new staff. To that end, they engaged CRI® Group’s EmploySmart^TM services, providing thorough and extensive pre-employment background screening in verifying prospective candidates’ experience and credentials. What happened next is eye-opening for any business leader.

CRI® Group’s agents uncovered disturbing details regarding one of the applicants. When CRI® Group contacted this individual’s former employers, one of them reported that the applicant had been hired without any prior experience, was trained for a couple of months, and then terminated due to committing cash embezzlement as well as participating in harassment and workplace violence. In other words, he was an employer’s nightmare!

Further checks revealed more problems at other organisations – CRI® Group discovered that the individual had been terminated from a second position after causing a financial loss at the company. By using EmploySmart^TM, the client dodged a major bullet and avoided hiring someone who could have done serious damage, both financially and to the company culture.

What you don’t know can hurt you

A dishonest employee could be unqualified for the position, possibly endangering others on the job. Or they might be a fraud risk, willing to bend the truth in other ways in order to enrich or advance themselves on your dime.

At CRI® Group, our EmploySmart^TM pre-employment background screening process analyses a job candidate’s claims and credentials, and digs beyond the surface to make sure the facts match up. Our experts conduct extensive checks that examine all of the following details of a potential employee:

• Verification of address
• Verify name and date-of-birth
• National ID number
• Credit checks
• Previous employment verification
• Credentials verification
• Bankruptcy checks
• Civil litigation checks
• Criminal history
• Record checks
• Professional qualifications and memberships
• Criminal background checks
• … and more.

Resume fraud: More common than you think

In another case study, CRI® Group’s investigators conducted background screenings of employees who were working for a multinational organisation operating in Pakistan. While verifying education credentials is just one of the aspects of the EmploySmart^TM process, the investigators immediately noticed red flags and initiated detailed checks of the education degrees claimed by the subjects.

In this case, CRI® Group screened 18 degrees claimed from a single university. By contacting the university and conducting an examination of documents and records, CRI® Group found an astounding 5 of them (27.7 percent) to be fake and/or forged. As it turns out, the following are some of the most common areas of resume fraud:

• Stretching dates of employment
• Inflating past accomplishments & skills
• Enhancing job titles & responsibilities
• Education exaggeration & fabricating degrees
• Unexplained gaps & periods of “self employment”
• Omitting past employment
• Faking credentials
• Fabricating reasons for leaving previous job
• Providing fraudulent references
• Misrepresenting military record

Resume fraud is a widespread problem for employers in every industry, and at any size company. It’s persistent and sometimes even careful examination of a resume won’t immediately reveal red flags or problems. The only way to properly vet job candidates is to screen them with a thorough pre-employment background screening process.

 Hiring process is Trusting, but verifying

No organisation can afford to have employees on staff who aren’t what they claim to be. Even a seemingly innocent embellishment can indicate more background problems under the surface, and the potential for future problems down the road.

Every business leader should embrace the need to EmploySmart^TM. Your greatest resource is your employees. Make sure they are who they say they are, and that you only hire the best.

Take a proactive stance with the highest level of Employee Background Screening as a part of your essential business strategy.  Contact us today to learn more about our full range of services to help your organisation stay protected. Get a FREE QUOTE

CRI® Group has safeguarded businesses from any risks, providing investigations (i.e. insurance fraud), employee background screening, investigative due diligence, business intelligence,  third-party risk management, forensic accounting, compliance and other professional investigative research services.

Filed under: Background Investigation, Due Diligence, Employee Background Check, Resources by admin
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