India’s Central Vigilance Commission (CVO), with its mission to “Help Realizing Dream of Corruption Free India” is ratcheting up its corruption prosecutions.
For example, it recently arrested a junior civil engineer for accepting bribes to approve a contractor’s pending bills. The CVO also charged a revenue inspector for accepting bribes to correct government property records. In May of this year, according to the India Times, the CVO “laid a trap” to catch a corrupt tourism officer for accepting bribes to approve a building for tourism. See e.g. India Times.
Laying traps to snag corrupt officials is a great way to prove a case and to send the message that the CVO is vigilant in its fight against corruption. These recent CVO investigations and arrests also show that businesses operating in India and elsewhere need to be vigilant in avoiding corruption by assuring that all employees who may interface with government officials appreciate and can identify corruption risks.
Many times when an organization is designing or implementing an anti-corruption ethics and compliance program, it only focuses on those in its organization who are actually selling to governments. Thus, all the anti-corruption policies, procedures, training and communication are directed to the sales team or business development professionals.
Firms take this approach because sales and business development folks are an obvious target of corrupt government officials, who may ask for a bribe in exchange for awarding a contract. But this approach to anti-corruption is myopic since it fails to consider the other ways a business interacts with government officials.
When analyzing the CVO’s recent arrests for corruption, it is evident that those in the government beyond government procurement officials are also positioned to ask for bribes. All your employees and third parties who encounter government officials need to be trained on how to spot issues in a transaction with a government official and your policies and procedures should be designed to help those employees manage the corruption risk.
Who are some of those other employees that an organization may not consider at risk of corruption exposure? The CVO arrests identify some of those employees.
First, the CVO arrested a junior civil engineer for seeking a bribe in exchange for paying the contractor’s invoices. This shows that finance folks need anti-corruption training and must be subject to appropriate corruption identifying and mitigating policies and procedures. They may be exposed to government officials; and they are the ones that see financial transactions that may be suspicious.
Second, as evidenced by the CVO’s arrest of a “revenue inspector” for seeking bribes around property boundaries, employees who are responsible for facility management, utilities management, environmental compliance, health and safety compliance may also interact with government officials regarding permits and certifications. They too should be trained on corruption and spotting corruption risk.
Finally, those in your organization who plan meetings, events and travel need to also be alert regarding issues of corruption as demonstrated by the CVO’s arrest of the Indian tourism official.
These are just some examples of employees who interact with government officials. There are many more employees and third parties in your business who may interact with government officials as part of their jobs. So you need to look across your business and think broadly as you analyze how it operates in order design an effective anti-corruption program. Doing so will help ensure that all of your employees and third parties who may possibly interact with government officials are knowledgeable of and vigilant against corruption.
By the way, a public service announcement: if you are doing business in India, the CVO has an informative and interactive website on combating corruption. It even has a Facebook page where people can file complaints or concerns (including anonymously) about matters of corruption. Check it out: Central Vigilance Commission
Until next time…. Behave.