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People bribe, not companies. Companies only provide the framework within which an offence might take place, and sometimes the motive. Whilst compliance regimes and internal business process have major roles to play, ultimately it is one or more people in the company or organisation that will decide to act improperly, perhaps on impulse. Such circumstances may also foster other offences, especially fraud and anti competitive behaviour. Most of our understanding of bribery and corruption is gained from case studies and is therefore historic by nature. Furthermore it is possible that some evidence may remain undiscovered or is not admissible in court. It is therefore difficult to persuade companies and especially those that have not experienced an allegation, to take measures (where not already in place) to mitigate such risks. This presentation sets out to examine the reasons and circumstances behind the actions of the “One Bad Apple”, the process and managerial weaknesses that might prevail and how by looking before the event and from within an organisation, ACAs might take new investigatory approaches and work more closely with companies to develop preventive strategies.
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