Adequate Procedures, Bribery Act & Proceeds of Crime - Written by on Wednesday, August 24, 2011 23:21 - 2 Comments

Whistleblowing web sites – how they could help Bribery Act compliance

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By Neil McInnes, Senior Associate, Pinsent Masons

China Daily has reported that, after blocking them, some bribe reporting sites in China have been granted approval by the internet authorities.

These sites are *very* popular.

In June the site in China was reported to have received 200,000 visitors in its first two weeks of operations. Its forerunner and inspiration from India,, has logged over 11,000 alleged bribery incidents so far.

Web and telephone based reporting tools fall in to a number of categories.

  1. First, there are those such as Trace’s Bribeline, which are anonymous online questionnaires that gather intelligence on the prevalence and occurrence of corrupt activity.
  2. Secondly, there are others that are publicly-viewed, blog-style reports of individual bribery incidents, collated with various types of analysis.
  3. Third, there are regulator-based hotlines, designed for the public to report criminal activity to the police. These include the SFO’s fraud reporting telephone line and the City of London Police Overseas Anti-Corruption Unit Reporting Line.  Last week we reported the Scottish initiative to encourage Facebook reporting.
  4. Finally, there are private sector hotlines and web tools that companies are increasingly subscribing to so their employees (and third parties) can report corruption concerns faced by them or their organisations.

Can these sites help Bribery Act compliance

What impact do the public web-based reporting tools above have on adequate procedures under the Bribery Act?

Can they help a company doing business in particular territories?


They shine a spotlight on the prevalence of different types of corruption, refined to a local level. On some sites methods by which bribes are demanded can be seen in detail and then assessed by the reader.

Lessons can be learnt and preventative strategies could be formulated based on the stories published online.

In the longer term, the sites could reduce demand-side corruption if there is a risk of those demanding bribes being named and shamed.

The results of some of the sites’ reports clearly have other benefits too in terms of risk assessment.

Trace Bribeline reports exist for Brazil, Mexico, Ukraine, Russia, India and China. The analysis varies from cohorts of around 100 to 300 bribe reports per territory. Not a vast number but the statistics are compelling. They include results for how often a person has faced demands for bribes – and the spread in most of these territories would shatter any illusions that exposure to corruption risks is simply one off demands and isolated incidents.

Most respondents have been asked for a bribe before. Some more than 100 times.


For those who confess to paying bribes, there may be a risk they are identified from their own reporting and investigated.

This does not appear to have deterred anyone so far.  The greatest risk is for those reported.  Regulators are alive to the intelligence they can pick up from these sites.  The Director of the SFO has encouraged people to use Twitter to report bribery…

Organisations may also find there are due diligence enquiries that are possible through targeted searches of some sites, which could supplement other fact-finding.

We are sometimes faced with the assertion: in some jurisdictions, say India, bribery is the culture.

Our reply.

Would the business like to appear on the internet reported on a social media bribe reporting website?



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James Vine (@JamesPSVine)
Aug 24, 2011 23:44

India’s is worth a mention. very successful apparently. (Hope I spelled it right!)

Weekly Roundup | i-Sight Investigation Software Blog
Aug 26, 2011 5:01

[…] Whistleblowing web sites – how they could help Bribery Act compliance: Neil McInnes, Senior Associate, Pinsent Masons,, discusses whistleblower websites and the various ways they can help with Bribery Act compliance. […]

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