In light of FSA’s record fine against Aon, Robertson & Co. issued advice to other companies
Robertson & Co. submitted the following advice to companies to help them avoid bribery and corruption risks.
Gavin Robertson, chief executive of Robertson & Co. recommended that companies:
Establish a clear policy attached to a statement of ownership by the Board that all staff are accountable and responsible for their actions and that corrupt conduct will be ruthlessly dealt with. The policy should be regularly tested as part of a compliance audit.
Foster a culture whereby all employees are encouraged to report wrongdoing and will be rewarded as opposed to victimised for so doing.
Ensure that employees who make reports of wrongdoing are forensically debriefed by an independent specialist in order to establish and validate the motive behind the allegation, preserve the integrity of any evidence and to protect the employer from any subsequent allegations of threat, intimidation or inducement.
Introduce systems whereby the giving or receiving of unlawful inducements can be prevented or quickly identified. The focal point for this is where has the money gone or where has the money come from – there must be an audit trail – if there isn’t then there may be a problem.
