Slightly more than half of companies report testing the effectiveness of their anti-corruption programs on a regular basis

Important elements of an effective compliance program are periodically reviewing the contents of the program against evolving risks and regulatory requirements, and monitoring/testing the program to identify and improve deficiencies. While a significant majority of companies (74%) reported regularly reviewing the content of their anti-corruption programs, only 55% regularly tested their programs for effectiveness.

Notably, 9% of companies stated that they have never tested the effectiveness of their anti-corruption program.

Responses also show uncertainty among companies regarding the frequency of anti-corruption program reviews and testing, with 12% of respondents unsure of the frequency of anti-corruption program reviews, and 15% of respondents unsure of the frequency of compliance program testing.

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Anti-corruption program testing: trends by company size

The largest companies prefer to test on a periodic or annual basis.

Three in four companies with revenues exceeding US$50 billion (75%) conduct periodic or annual testing, with 50% preferring periodic testing. No company in this size class reported "never" testing its anti-corruption program.

In comparison, smaller companies were more likely to test on an ad hoc basis, if at all. 16% of companies with less than US$1 billion in annual revenues reported "never" testing their anti-corruption program. Less than half (45%) of these companies perform periodic or annual reviews.

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A minority of companies use sophisticated techniques to test anti-corruption program effectiveness

Companies are more likely to use traditional anti-corruption program testing techniques including the use of internal audits (60%); review of compliance training and certifications (50%); and review of hotline usage (40%).

Conversely, less than one-third of respondents reported using more sophisticated techniques for evaluating compliance program effectiveness with respect to day-to-day operations, such as transaction testing (32%) and third-party audits (24%).

Only one in five (20%) said that they evaluate employee requests to Compliance and Ethics teams for consultation or approval.

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