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

When people think off bribery and corruption, they often imagine the exchange of suitcases full of money in dark alleys or invitations to lavish trips or events. The topic is also more 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 makes it easy to think that “this doesn’t happen here”.

Yet, 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 say they had either been asked to pay a bribe or had lost an opportunity to a competitor who 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 said that they do not have a programme to address bribery and corruption risk and half of all respondents either perform no or only informal third-parties due diligence. Fewer than 3 in 10 companies perform limited testing of the operating effectiveness of their controls, and another 12% do no testing at all.

PwC's Academy offers a training to raise awareness for the risks of bribery and corruption that companies and institutions face in Luxembourg and to explain how to manage those risks. The training gives an overview of international legislation 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 Roxane Haas and Michael Weis, partners at PwC Luxembourg and will be given by directors and managers who benefit from a strong professional experience in this area.

Roxane Haas is a “réviseur d’entreprise agréé” and accountant in Luxembourg. Roxane is an audit partner at PwC Luxembourg. She has over 14 years of professional experience at PwC in particular in the context of audits of banks, PSF and investment funds. She is also in charge of the taskforce AML PwC Luxembourg and is active in local working groups (Luxembourg Association of Compliance Officers, Institute of Company Auditors and Institute of Chartered Accountants). Her skills have brought her to supervise many AML/KYC missions for major banking players of Luxembourg.
Over the past 10 years, Roxane has conducted numerous AML trainings for both national and international professional organisations.?

Michael Weis is a partner in the forensic services. Through his previous positions and projects, Michael 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 programme that regularly involves international subject matter experts (e.g. transparency international, UN Security Council, FATF, SCPC, FSA, CSSF etc.).
Through his professional qualifications he specialised in compliance related topics such as internal controls frameworks, fraud prevention/investigation and AML.