What is "Anti-Bribery Training"?
Updated: Jun 27, 2022
Ethena's latest webinar covered our newest training content: Anti-Bribery & Corruption
Last month, Ethena launched our newest course, Anti-Bribery & Corruption, our first course since Harassment Prevention. And while most Compliance and Ethics fans know what to expect with Harassment Prevention training, not everyone knows that Anti-Bribery training might entail.
To celebrate our launch, we pulled together three of our experts on the subject, Leonard Shen, Jannie Lung, and Austin Light (along with Ethena CEO Roxanne Petraeus) to break down what makes Anti-Bribery training effective and why it matters now.
For any company that works with government officials, Anti-Bribery training is more important than ever.
It can be easy to assume that, when looking over a host of compliance requirements that need to be met on an annual basis, a course like Anti-Bribery–one that is surprisingly not legally required in the US–would be low on the priorities list. But for US-based companies, regulation of the FCPA has only gotten more intense over the past decade, and it’s not going anywhere, according to Leonard Shen:
I would have assumed that [during the Trump administration], there would have been a diminution of the fairly aggressive billion dollars of fines that have been accrued under the previous administrations. But in fact . . . there was actually at least a doubling or a tripling of the number of individuals charged on the FCPA and of the fines both civil and criminal that were brought against corporations. So it’s been a very very active field.
And it’s not just the previous administration. We can expect FCPA enforcement to get even more thorough over the next four years: “Just this past couple of months, the Biden administration has made some very bold statements about how it’s planning to take the Anti-Corruption enforcement area even further.”
If you’re a compliance officer worried about the FCPA, investing early in regular Anti-Bribery & Corruption training could save you millions in legal fees and billions in fines.
“The first thing to keep in mind is that the quality of the training matters.”
It goes without saying that compliance and ethics teams want nothing but the best, most relevant training for their employees. But it can be difficult to discern what really counts as “effective training” when training on something like Anti-Bribery that doesn’t have set regulations to meet.
Do you simply spell out the law and its consequences, or is there a better way to assess the options available? When asked about how she has approached building these programs, Jannie explained that it’s just as important to make sure employees know what it means to bring this training to everyday work: “[When it comes to assessing a new training program,] not only do I expect to see a comprehensive breakdown of what the law actually entails or enforces, but I want to see how employees can convert this knowledge into practice.”
Modern Anti-Bribery training is more than just “don’t take the shady envelope of cash”; there’s a lot of nuance to cover.
Attendees of the webinar were treated to a two-minute music video (check out the full recording below!) on the subject of bribery and how bribes are often less obvious than you might think. A Target gift card for the mayor’s wife might seem harmless enough. But Austin Light noted that Anti-Bribery training is most effective when it covers the little things, and Ethena’s training made sure to start there:
I think what we did with this training . . . was to think about those small, gray areas, to think about the nuance. . . . Not everybody is going to be involved in a $50M deal with a foreign official at their company. But [incidents of bribery and corruption are] smaller than that in most cases . . . It’s kind of like trusting that little wiggling doubt they might feel and say “ooh, I need to go talk to the compliance person in my company to make sure this is okay.”
Ethena is no stranger to targeting gray areas–fans of our Harassment Prevention course might remember a number of nudges dedicated to more nuanced areas like “Online Harassment” or “Allyship.” And our team took a similar approach to building this course. Starting with the small things helps employees recognize bribery and corruption in daily life, giving them confidence to speak up when it really matters.
Interested in Anti-Bribery training? Check out our Courses page! And take a look below for a full recording of our webinar.
(For anyone looking for the book recommendation Roxanne mentions on the call, check out Humor, Seriously.)