Anti-bribery and corruption: necessity, benefits and instruments of an anti-bribery and corruption programme

When people think of bribery and corruption, they often envision the exchange of suitcases full of money in dark alleys or invitations to lavish trips or events. The topic is also commonly associated with less developed countries or only certain sectors like construction or sports. The fact that Luxembourg consistently scores high in the Corruption Perception Index might lead some to believe that 'this doesn’t happen here'.

However, bribery and corruption often take much more subtle forms, e.g. the exchange of favours and information, concealed payments or circumvention of normal procedures.

In our global economic crime survey 2020, one-third of the respondents reported either having been asked to pay a bribe or losing an opportunity to a competitor whom they believed had paid a bribe.

Bribery and corruption are among the top types of experienced frauds. Out of the companies accused of committing a financial crime, corruption was one of the most frequent charges.

Still, most companies admit to lacking a programme to address bribery and corruption risk with half of all respondents either performing no due diligence or only informal third-parties due diligence. Fewer than 3 in 10 companies conduct limited testing of the operating effectiveness of their controls, and another 12% perform no testing at all.

PwC's Academy offers a training to raise awareness of the risks of bribery and corruption that companies and institutions face in Luxembourg and to explain how to manage those risks. The training provides an overview of international legislations on the topic and tips for implementing a robust compliance programme.

By the end of the course, participants will be able to:

• explain the different forms of bribery and corruption;
• understand their extent in an international and national context;
• identify suspicious behaviours or suggestions;
• be more vigilant in their day-to-day tasks.

This module covers the following:

• Overview of different forms of bribery and corruption
• International and national laws, regulations and penalties
• Components of an anti-bribery and anti-corruption programmes
• Requirements in other countries and sectors that can serve as a model
• Governance structures and internal controls
• Third party due diligence
• Risk assessments
• Case studies and discussion

An attendance certificate will be sent to participants.

This training is coordinated by Michael Weis, Partner at PwC Luxembourg and will be given by directors and managers who benefit from a strong professional experience in this area.

Michael, Financial Crime Leader and Partner in the forensic services, gained extensive knowledge in the investment management and banking industries.

As a key member of the internal controls practice of PwC, Michael specialises in the review of internal controls in the context of SAS 70 reviews and controls reports. He is the manager of various high-profile client assignments on internal controls reports and on Anti-Money-Laundering (AML) in the investment management industry.

Within PwC, Michael takes a key role in the AML taskforce and on internal controls work for the prevention of financial crime. He is coordinating the PwC’s Academy's “Fight against financial crime” leading training programmes that regularly involve international subject matter experts (e.g. transparency international, UN Security Council, FATF, SCPC, FSA, CSSF etc.).

Through his professional qualifications he specialises in compliance related topics such as internal controls frameworks, fraud prevention/investigation and AML.