Once the main components of an anti-corruption programme are in place, the directors and top management will want to know how well the system is working. This is to be fully expected since a programme which is ineffective could result in criminal prosecution under Section 17A of the MACC Act. Using the results of extensive research Trident has prepared an effectiveness testing approach designed to give confidence to the Board and management team that their anti-corruption programme is having the desired impact. Areas for improvement can also be identified using factual data. This helps the people in charge of the programme to strategise well and use their limited resources for maximum effect.
Several components make up our effectiveness testing approach. Our extensive Gap Analysis work identifies any shortfalls in the policies & procedures which need to be addressed. Then we use integrity surveys to identify the status of key elements of the programme and if there are indicators of corrupt behaviour occurring in the company. Enhanced auditing, and for some companies the use of data analytics, also helps build the picture of the company, identify to what extent the company has a culture of integrity and help establish the overall Level of Integrity of the company. These factors can also be used to identify areas of improvement, create the necessary action plans, and further build up the company to a position of strong integrity health.
Contact us to know more about our approach and how we can tailor the effectiveness testing to suit your current stage of anti-corruption programme development and size of organisation. With MACC Act Section 17A already in force it is an exercise worth doing even if your programme has only recently been established, as this will provide assurance to your directors that the programme is working and where it can be strengthened. It will also create a benchmark for future reference to see how the Level of Integrity is building up over time as your programme matures. An initial discussion might be all that is needed at this time, but it may be you are ready to move forward and this would be a good time to talk about it.