Anti-Corruption Compliance

An anti-corruption compliance programme in place demonstrates to investors that the organisation conducts its business responsibly, complies with ethical standards and has mechanisms in place to prevent non-compliance. This builds trust, reduces risks to investors and may become a decisive factor in approving a funding decision. Investors often consider reputational risks alongside financial performance, which is why a transparent compliance system is an important component of investment attractiveness.

PwC Forensic helps organisations create a transparent compliance system that meets international standards and improves the investment attractiveness.

Implementation of a compliance programme within the organisation requires the client to be actively engaged to ensure that the programme is successful, in particular:

• Demonstrating management buy-in: Management must show full commitment to the compliance programme, spearheading its implementation and being actively involved in its promotion.
• Being ready for change: Remaining open to revising and improving processes based on the recommendations received from the consulting team.
• Allocating resources: Making sure an appropriate budget, human resources and technological support are available for effective implementation of the compliance programme.
• Cooperating in assessing business process vulnerabilities: Providing relevant information and access to internal business processes.
• Defining key standards: Jointly defining ethical standards and policies that reflect the organisation's specific mission and values.
• Participating in defining policies and procedures: Collaborating in developing specific anti-corruption policies, procedures and reporting tools.
• Providing training: Facilitating and delivering training to raise staff awareness of anti-corruption regulations and the importance of meeting compliance standards.
• Monitoring and auditing: Incorporating procedures for periodic monitoring and assessment of the compliance programme.
• Setting up reporting tools: Establishing systems for anonymous reporting of offences that protect whistleblowers from retaliation.
• Managing third-party contacts: Ensuring that third parties and business partners follow similar anti-corruption standards.

The first step is to establish an internal working group or appoint a person responsible for anti-corruption compliance.

The next step is to conduct a comprehensive corruption risk assessment, taking into account the specific nature of the company’s business processes, as well as its interactions with government authorities, suppliers, and business partners. Based on the results of this assessment, core policies, procedures, and a code of ethics should be developed to reflect the organisation's values and its commitment to integrity.

PwC Forensic provides support at every stage — from risk assessment to the development of policies and the implementation of an anti-corruption compliance programme tailored to the specific needs of your organisation.

The following basic steps are a good starting point:

1. Developing a Code of Conduct;
2. Updating standard policies and procedures;
3. Delivering internal training.

It is important to ensure management buy-in, as tone from the top is key to building an ethical culture. Another good step would be to make use of available resources, such as public sources, industry recommendations and best practice examples.

PwC Forensic offers flexible support formats, from advice to ready-to-use solutions that are easily scalable and do not require significant upfront investment.

The programme should be reviewed at least annually and in response to changes in legislation, corporate structure or newly identified risks. Regular updates will allow the organisation to respond to new challenges, adapt its policies to changes in business environment and keep the measures taken relevant. In addition, it demonstrates the organisation's commitment to integrity and responsible business practices.

PwC Forensic assists organisations in periodic reviews of their compliance programmes and provides recommendations to improve these programmes and adapt them to changes in the environment.

Yes, even if the company works solely in the domestic market, it still needs compliance. This is because corruption and fraud risks exist that may arise in interactions with government authorities, suppliers and contractors. By having a strong compliance programme, the company may avoid legal issues, whilst also maintaining its business reputation, which is critical to continued long-term success. Additionally, such programmes help establish ethical behaviours and corporate culture to ultimately reduce the the risk of fraudulent behaviour by employees. 

PwC Forensic experts can adapt compliance solutions to the scale and specific nature of your business, making them effective and relevant to the specific requirements and local operating conditions. 

To set up a whistleblowing channel, choose a secure, encrypted platform for anonymity, draft a clear reporting policy, and appoint impartial personnel to manage cases. Implementing a reliable system requires careful planning and execution:

• Assess legal requirements: depending on your location and headcount (such as the EU Whistleblowing Directive's requirements for companies over 50 employees), specific legal parameters must be met.
• Choose secure technology: utilise dedicated whistleblowing software or hotlines that guarantee anonymity, end-to-end encryption, and offer unique tracking codes for reporters.
• Draft a compliance policy: create a comprehensive policy detailing the scope of what can be reported, the rights of the whistleblower, and strict zero-tolerance rules for retaliation.
• Appoint impartial case managers: assign trusted, independent internal staff (like compliance or legal officers) or an external partner to receive and triage complaints.
• Educate employees: communicate the existence of the channel through company intranets, employee handbooks, and regular training.

PwC supports organisations in building whistleblowing systems that are legally sound, fully confidential, and trusted by employees — reducing the risk of regulatory penalties and ensuring issues surface before they escalate.

The anti-corruption programme allows the organisation to systematically identify, assess and mitigate risks related to corruption, fraud, conflict of interest and lack of integrity. It creates controls, transparency and accountability tools that reduce the likelihood of non-compliance and increase business resilience. Additionally, anti-corruption compliance contributes to establishing a culture where risks are prevented rather than responded to after the fact.

PwC Forensic assesses risks, develops risk management policies and supports the implementation of strong controls.

To make a compliance training effective, it should be regular, skill-oriented and relevant to the employees' roles. It is important to use real-life case studies, interactive formats and gather feedback to improve the curricula. In addition, the training must be incorporated into the overall L&D strategy, including internal communication campaigns and the integration of anti-corruption themes into daily activities.

PwC Forensic delivers training events and workshops and develops training materials, including online modules tailored to your business needs.