Financial Crime World

Compliance Officer’s Guide to Ensuring Effective Anti-Corruption Programmes in State-Owned Enterprises

A comprehensive anti-corruption programme is crucial for state-owned enterprises (SOEs) to maintain public trust, prevent reputational damage, and ensure compliance with national laws and international standards.

Step 1: Risk Assessment

To develop an effective anti-corruption programme, it’s essential for compliance officers to gain insights into the enterprise and its main risk areas. This involves:

  • Familiarizing themselves with the organization’s structure, operations, and stakeholders
  • Conducting interviews with employees
  • Reviewing company documents
  • Analyzing industry trends

Step 2: Developing the Anti-Corruption Programme

The anti-corruption programme should align with national laws, international standards, and the SOE’s ownership policy. To ensure commitment from across departments and hierarchical levels:

  • Involve a broad set of employees in the development process
  • Develop interview guidelines to gather feedback from stakeholders
  • Share aggregate results outlining how the feedback will shape the anti-corruption programme

Step 3: Oversight

Oversight is critical for ensuring that the anti-corruption programme is efficiently implemented and that employees comply with it, as well as business partners. To achieve this:

  • Work with senior management to encourage fulfillment of oversight responsibilities across the SOE
  • Ensure that executive management and the board have ultimate responsibility for overseeing and ensuring effective implementation

Best Practices

To ensure successful implementation of anti-corruption programmes:

  • Develop clear and easy-to-understand language in the programme
  • Ensure equitable application of rules and principles across all levels, functions, and areas of the SOE
  • Avoid double standards in policy interpretation
  • Provide adequate resources for overseeing the programme
  • Regularly review and update the programme to reflect changes in the organization’s structure, operations, or stakeholders

By following these steps and best practices, compliance officers can help ensure that SOEs develop effective anti-corruption programmes that prevent corruption, promote transparency, and maintain public trust.