Last week we wrote about the consultation currently taking place in relation to the proposed new BSI Standard for Anti-Bribery Adequate Procedures and posed a number of questions.

In this guest piece Jeremy Crame, CEO of Hitec Laboratories,developers of Risk & Compliance software solutions poses another question about the scalability of the BSI requirement for all employees to sign declarations and offers a potential solution.

BTW we are unconvinced it is necessary, appropriate or proportionate for all employees to sign declarations (for example what about employees who have little or interaction with third parties).  However, there is no question that IT systems can help with scaling your compliance program.

By Jeremy Crame, CEO of Hitec Laboratories

Whilst a set of well researched and drafted Policies & Procedures are clearly a cornerstone of a corporate UK Bribery Act compliance programme, they become less valuable if there is no clear and demonstrable communication, knowledge assessment and audit process in place.  In other words implementation is key.

The British Standards Institute (BSI) will soon be issuing BS10500, which is targeted at managing a corporate anti-bribery programme. Time will tell whether this becomes widely used by organisations – there are a number of questions in relation to it.

In its current draft form, the proposed BSI Standard includes some important and very sensible procedural guidelines.

Refreshingly, the draft also expands on the contents of Principle 5 contained in the Ministry of Justice Guidance, and includes guidelines on communication and knowledge assessment, and includes a requirement that every member of staff completes a compliance declaration.  This latter requirement is a potentially heavy burden for companies.

Achieving compliance with The Bribery Act can be a challenge for medium and large organisations that have large numbers of employees and partners scattered around the globe.

There is a potentially serious scalability issue.  Corporate intranets, emails and manual systems may simply be insufficient.  In these straightened times employing an army of additional compliance staff is not on the radar.

Against this backdrop it appears that, for many companies, the best way of successfully complying with, and surviving an audit based on, BS 10500 economically, is likely to be to implement a software based solution that automates and reports on, a lot of the processes.

It is likely to be the case that other non BSI Standard approved programs would similarly benefit from the use of a software based solution.  We’re helping clients meet the practical challenges they face implementing their programs.

Jeremy Crame is CEO of Hitec Laboratories, developers of Risk & Compliance software solutions. He may be contacted at +44 (0)1628 600900 or by email at jeremy.crame@hiteclabs.com