In today’s global business environment, even a rumour or a viral social media post can severely damage corporate and brand reputations, impacting shareholder value within moments. Protecting against reputational risk begins with leadership setting the right ethical tone.

Without a strong culture of integrity, organisations may treat compliance as a mere formality rather than a fundamental business requirement.

Our Client

Our client is a leading provider of power generation solutions in the Middle East and Asia. They specialise in supplying and servicing gas and diesel generators, industrial automation solutions, and renewable energy projects. As a significant player in Pakistan's energy sector, our client has established partnerships with global energy brands and has been involved in major infrastructure and industrial projects. However, its operations have been scrutinised due to allegations of financial misconduct and improper business dealings, raising concerns among international stakeholders and regulatory bodies.

The Challenge

In late 2018, a Pakistani Joint Investigations Team (JIT) uncovered that our client had facilitated money laundering for a former President and the Minister for Law & Justice. The scandal involved approximately US$250 million in embezzled funds, with illegal payments concealed through fake accounts. Our client was implicated in making 13 payments, amounting to over US$800,000, to the son of the Minister for Law & Justice.

Following the scandal, our client formally committed to abstain from bribery and corruption. However, implementing this commitment proved challenging due to cultural differences in defining corruption. Local business practices in Pakistan often viewed bribery as a necessary cost of doing business rather than an ethical violation.

Employees openly admitted to making facilitation payments to customs and law enforcement officials, believing that these payments merely expedited processes rather than constituting corrupt acts. This perception was even endorsed at the board level, reinforcing the notion that such payments were an inherent part of conducting business in the region.

Our Approach

To address these challenges, we were engaged to develop an effective Anti-Bribery and Corruption (ABC) programme. This included drafting a new ABC policy and an associated Code of Conduct tailored to the organisation’s global operations. The ABC policy covered:

• Expected standards of behaviour.

• Escalation procedures.

• Conflicts of interest.

• Expenses, gifts, and entertainment policies.

• The use of third parties to win business.

• Whistleblowing mechanisms.

• Monitoring and review processes.

• Disciplinary actions for non-compliance.

The policy was designed to be flexible in recognising cultural differences while maintaining ethical business practices. A country-specific gift and hospitality matrix was developed to guide employees on acceptable limits across different regions, ensuring proportionality based on the local cost of living.

To embed compliance throughout the organisation, we collaborated with management to establish a mandatory annual attestation process, requiring all employees - regardless of position - to confirm their understanding and adherence to the policy. The policy was translated into all relevant languages to facilitate accessibility.

To ensure long-term effectiveness, we recommended continuous monitoring through key risk and performance indicators. A reporting dashboard was implemented to provide senior management with real-time insights into bribery and corruption risks.

Additionally, we developed a Code of Conduct with a dedicated section on reporting actual and potential violations. To reinforce understanding, all employees received training on the policy and Code of Conduct, delivered in both English and Urdu across all company locations.

Key Benefits & Measurable Outcomes

By implementing a robust ABC programme, our client has achieved significant improvements in compliance, transparency, and ethical business practices. Key benefits include:

• Enhanced Corporate Governance: Clear policies and procedures have strengthened internal controls and accountability across all levels of the organisation.

  
  

• Cultural Alignment with Compliance: By tailoring policies to local customs while maintaining ethical standards, employees are more likely to engage with and adhere to compliance requirements.

  
  

• Strengthened Reputation &Stakeholder Trust: Proactively addressing bribery and corruption concerns has improved relationships with regulators, investors, and business partners.

  
  

• Real-Time Risk Monitoring: The implementation of a reporting dashboard provides senior management with data-driven insights, enabling swift decision-making to mitigate risks.

  
  

• Consistent Ethical Standards Across Borders: The policy’s accessibility in multiple languages ensures that all employees, regardless of location, understand their obligations.

  
  

• Increased Employee Engagement and Awareness: Comprehensive training initiatives have embedded a culture of integrity, empowering staff to report misconduct without fear of retaliation.

  
  

• Reduced Legal & Financial Risks: Stronger compliance measures minimise exposure to penalties, regulatory action, and financial losses linked to bribery and corruption.

  
  

Ensuring ethical business practices is not just about mitigating risk, it is a strategic advantage. A well-implemented ABC programme builds credibility, safeguards reputations, and enhances business resilience in high-risk markets.

Strengthen Your Organisation’s Compliance Framework

Need help in strengthening your organisation’s ABC framework? Contact us today to safeguard your business against reputational and financial risks.