Good conduct and culture are not just a regulatory requirement for firms. It also provides firms with a competitive advantage – customers are more likely to choose firms they believe will treat them fairly. So monitoring and focusing on the actual outcomes of staff conduct is crucial for firms today.
Regulators expect senior management to understand the bribery and corruption risks faced by their firm, the materiality of the risks to its business, and the extent to which the firm’s anti-bribery and corruption systems and controls are adequate and effective.