Increasingly companies around the world are being required to improve their procedures and policies to avoid participating in bribery and corruption. The US government is enforcing its Foreign Corrupt Practices Act – in 2010, the US imposed a total of US$1 billion in penalties under this act. And in 2009, a UK insurance company was fined more than UK£5m for bribery. In giving this penalty, the UK Financial Services Authority advised the insurance company that it
“should have ensured that appropriate members of staff … received focused training in relation to this area and were tested on their understanding of the relevant risks involved. Effective training and testing in this regard would have emphasized to staff the importance of carrying out effective due diligence”
Assessments can help in two main ways. First, as indicated above, a quiz or test after training allows you to confirm that the training has been understood. This is put very well in an excellent 2010 blog article from the US lawyers Jones Day who said:
Part and parcel of adequately communicating and training on company policies and processes is assessing the effectiveness of the training. At a minimum, a meaningful training assessment includes a “quiz” during or at the end of the training that is “graded” to ensure that the employee has learned at the least the required concepts. The results of such grades also provide important feedback regarding the content of the training materials and where the training needs to be clarified or improved.*
Secondly, employee surveys including course evaluation surveys, employee attitude surveys and quizzes that allow comments can enable employees to alert you that something may not be right. UK Ministry of Justice guidance says:
Staff surveys, questionnaires and feedback from training can also provide an important source of information on effectiveness and a means by which employees and other associated persons can inform continuing improvement of anti-bribery policies.
As of July 1st (this Friday), the UK is introducing its new Bribery Act, which strengthens the law in the UK. An interesting facet of the new UK law is that it applies to companies that do business in the UK, not just UK companies. If companies implement anti-bribery prevention procedures, they get protection from the law, so there is an incentive to put in effective procedures.
Here is a quiz to help you learn about the UK Bribery Act; the quiz will be slightly different each time you take it as some of the questions are pulled from a pool at random. Feel free to answer the quiz embedded in the blog below or pass on the URL to colleagues as www.questionmark.com/go/briberyact. This quiz won’t let you master the Bribery Act on its own, but quizzes and tests like this one can help ensure that your employees understand the rules help them follow them.
*Jones Day have not reviewed nor endorsed this blog post.