This section provides guidance in relation to the requirement that an organisation should provide appropriate anti-corruption training on a regular basis to all relevant personnel to make them aware of the types of corruption they could encounter, the risks of engaging in corrupt activity, the organisation’s anti-corruption policy and procedures, and how they may report corruption (Measure 8 of the Anti-Corruption Programme for Organisations).

For access to GIACC’s free on-line training module, see Training Resources.

(1) Training the organisation’s personnel

The organisation should provide appropriate anti-corruption training to all relevant personnel, including:

• personnel who are responsible for implementing parts of the anti-corruption programme; and
• personnel who could encounter corruption in relation to their duties.

The purpose of the training is to make relevant personnel aware of and understand:

• the organisation’s anti-corruption policy;
• the organisation’s anti-corruption procedures which are relevant to their role;
• the risks and damage to them and the organisation which can result from corruption;
• the types of corruption they could encounter;
• the circumstances in which corruption could occur in relation to their duties, and how to recognise these circumstances;
• any necessary preventive and investigative actions they need to take in relation to any corruption risk or suspected corruption;
• how they can avoid corruption;
• how and to whom they should report any concerns.

This training should be provided to new personnel as soon as possible after they join the organisation.

In the event that any of the organisation’s existing personnel are assigned to a new role within the organisation which may result in increased anti-corruption risk or responsibilities, then they should be provided as soon as possible with training appropriate to their new role.

This training should be repeated at reasonable intervals so that personnel remain aware of the issues and their responsibilities.  It would probably be appropriate for personnel to have an annual training session.   Either the full training could be repeated annually, or the personnel could receive the full training initially and then have appropriate follow up or refresher training annually.

“Training” does not necessarily mean formal training in a classroom environment. It includes any appropriate type of training, guidance or awareness raising.   The formality and extent of the training depends on the size of the organisation and the corruption risks faced.  The key point is that all relevant personnel should understand the relevant issues.   One or more, or a combination of, the following methods can be used.

• In-person training:  In-person training is recommended for key personnel such as the board, and all personnel involved in roles, operations or processes with more than a low corruption risk. In-person training could be:
  • One-to-one:  The person giving the training can have a one-to-one session with the person receiving it.   Ideally, both people should be in the same place, but where distance makes this impractical or too expensive, then it can be by on-line communication methods (e.g. Skype or equivalent).
  • Workshop:  A group of personnel may receive in-person training at the same time. This has advantages, as it means that people can interact and share their experiences.  Ideally, all participants should be in the same place, but where distance makes this impractical or too expensive, then it can be by on-line communication methods (e.g. Skype or equivalent).
• On-line training module:  The training could be conducted by an on-line module.
  • The on-line module for personnel who face a low level of corruption risk could be short and simple, and could basically explain what the organisation’s anti-corruption policy is, the fact that an anti-corruption programme has been implemented, what types of corruption risk such personnel could face, how personnel should deal with the risk, and how to seek advice and to report concerns or suspicions.
  • The on-line module for personnel who face a higher level of corruption risk needs to be more detailed. In addition to the elements of the simple module above, it should also include detail on the types of higher risk corruption issues the personnel could face and how to deal with these.
  • Some organisations may have two on-line modules, one for low risk personnel and one for higher risk personnel.  Some organisations may only have a low risk module which all personnel (including higher risk) take, and then higher risk personnel receive a supplementary in-person workshop to inform them of the types of higher risk corruption issues the personnel could face and how to deal with these.

The training could take place as stand-alone anti-corruption training, or could be part of the organisation’s overall regulatory, compliance and ethics training.

It can in some cases be difficult to ensure that personnel undertake training, as personnel may wish to defer training until they have implemented their other day-to-day work priorities, and may not turn up to workshops, or may not complete on-line programmes by the specified dates.  It is important, therefore, for the organisation to ensure that personnel do undertake the relevant training.  Failure to complete training should be a disciplinary offence.  Training records should be monitored to ascertain which personnel have not taken the training, and personal intervention may be required from functional heads or top leadership to ensure that training is completed.

(2) Training personnel of business associates

Where the organisation is working with business associates which pose more than a low corruption risk to the organisation, the organisation should ascertain as far as reasonable that personnel of the business associate who are working on the relevant transaction have received appropriate anti-corruption training. Business associate personnel who do not understand the risks of corruption or the necessary preventive measures can pose a risk to the organisation.

This requirement is not easy to implement or verify, as the personnel of such business associates do not work directly for the organisation, and the organisation typically will not have direct access to such personnel for purposes of training or to verify that they have been trained.  The actual training of the business associate’s personnel will normally be conducted by the business associate, or by a third party for the business associate.

The organisation could take the following steps to implement this measure:

• Identify in the organisation’s corruption risk assessment which categories of business associate pose more than a low corruption risk to the organisation.
• In relation to each specific business associate which falls within this more than low corruption risk category, identify whether training of the relevant personnel of the business associate would help reduce the relevant corruption risks.  If it would, take steps to identify whether the business associate has provided appropriate anti-corruption training to its relevant personnel.
  • If it has, then the organisation is satisfied with this element.
  • If it has not, or if the organisation cannot verify whether it has, then the organisation:
    • if practicable should require the business associate to provide appropriate training to its relevant personnel (the organisation could require this in the relevant contractual commitment (e.g. joint venture agreement, sub-contract), or in a separate commitment);
    • If not practicable, then the absence of training, or inability to verify training, should be taken into account as a negative factor in the organisation’s risk assessment of the business associate.

The content of the training to be provided by the business associate for its personnel should include equivalent content to that referred to in section 1 above.

In the case of high risk business associates over which the organisation has a degree of control or influence, it may be appropriate for the organisation to require the relevant personnel of these business associates to take the organisation’s own training programme. In particular, this could apply to agents, distributors or other organisations which form part of the organisation’s sales process.

(3) Training records

The organisation should have a documented training procedure, and should keep records of compliance with the procedure.  These records could include, e.g. lists of participants at training workshops, content of training workshops and on-line training, records of personnel who have taken the on-line training, when the training was undertaken, and who gave the training workshops.

(4) Training resources

For access to GIACC’s free on-line training module, see Training Resources.