Anti-Corruption and Anti-Bribery

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APPENDIX 5-B: Considerations in Initially Planning or Reviewing Your Training Program

To begin your planning process or assessment it may be helpful to determine the following:

What are the objectives for the training?

☐ Support a culture of ethical behavior and compliance.

☐ Communicate a policy, requirement or law to raise awareness and improve compliance, also reduce risk. Provide practice in applying policy to realistic scenarios.

☐ To satisfy internal or external obligations or requirements.

☐ To help close a known gap in behaviors revealed in assessment, audit, or investigation.

What issues to cover and who to train?

What are the highest risks?


What current training exists?


How effective is existing training?


How will you address specialized or complex topics?


Will employees or others be learning processes and systems?


Who interacts with the risk and at what level?


In anti-corruption training, audience would focus on:

☐ Positions with high levels of discretion (board, senior management, CFO, Controller)

☐ Positions in countries considered high-risk (e.g., country managers, local finance, sales reps)

☐ Sales and marketing groups that operate in global environments

☐ Procurement and supply chain organizations (financial influence, many third-party relationships, etc.)

☐ Legal, finance, and ethics and compliance (must have a deeper knowledge of standards for advice giving and exercise of approval authority)

☐ Employees otherwise expected to be involved in situations where specialized or complex information is needed to manage specific risks (for ex. putting together a first time deal in a remote, high risk location)

☐ Third parties

What is the current training load for these individuals and how can you best access the employees?

How much learning needs to take place?


☐ Increased awareness plus where to go for help

☐ Deeper understanding and changed beliefs

☐ Application, advocacy and changed behaviors

How will you present materials, with what frequency and depth of content?

☐ Review of law, guidelines and best practices

☐ Consideration of how your population learns

☐ Provision of a variety of reinforcing approaches

☐ Setting of goals and plan to measure progress.

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