Companies need to take bribery and corruption very seriously to avoid incurring substantial settlements, costs or prosecutions. The starting point is to have structures and policies in place, to make risk assessments, to focus the attention of Compliance on this issue and for Internal Audit to report on this issue.

A whistleblowing system is invaluable so as to capture and deal with problems and where appropriate bring to the attention of relevant authorities for assistance and to mitigate penalties.