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 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 this training, 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 programme
• 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 leads PwC’s Forensic Services practice and AML taskforce, overseeing investigations, remediation projects, and high-profile AML audits for banks and investment funds. He is the key contact for AML distribution due diligence in asset management and works closely with PwC’s global forensic network on international projects. As certified fraud examiner, Michael is recognised as an AML and forensic expert and actively contributes to industry working groups on fraud at the Institute of Internal Auditors (IIA) and the Institut Luxembourgeois des Administrateurs (ILA). He regularly conducts workshops and training on AML and fraud in Luxembourg and abroad.