The FSA and Willis

The key message that comes out of the Final Notice issued last week to Willis by the FSA for failures in their anti-bribery systems is simple: the need for critical engagement. In other words, be sure to check, be able to gauge what you find and be willing to challenge.

An ever present danger in business ethics is the gap between pen and practice. It can be immense, for all sorts of reasons: your processes weren’t good enough, your people didn’t understand it and your people didn’t buy into it, are just three. So you can start out with the best of intentions, but unless there’s a well designed business objective in place, supported by checks to gauge your progress towards it, then a lot is being left to chance.

So how should you gauge progress towards a zero tolerance on bribery? Clearly not in monetary terms. One approach is to work at two levels – one set of checks to make sure your processes are being followed and another set of checks to make sure your people understand not just what they’re being asked to do, but why they’re being asked to do it. Personalising the process will make it mean something to employees and engage them in delivering the business objective.

I’m sometimes perplexed by the apparent inability of brokers to reflect upon the risks present within their own business. My suspicion is that the problem lies more with the reflect aspect than the risk aspect. So while I expect the Willis case will bring about a boost in anti-bribery training amongst brokers, I think it will be short lived in its impact if not accompanied by some form of parallel training in reflective and critical thinking.

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