Do you have customers getting special treatment?
There are different ways that customers can get “special” treatment. And this special treatment can be considered by the FCPA, the UKBA, the China anti-corruption act, or other laws as being commercial bribery. Commercial bribery can land your C-level employees in the region in jail. So, unless you don’t like your colleagues, let’s see how we can protect them.
The most obvious way to give customers special treatment is to give them too many free products or low-cost sales. This is especially common in FMCGsthat operate in countries with black markets.
Another way to give customers special treatment is to extend their payment terms. Sometimes your sales staff might agree with the customer to extend their payment term by 90 days, in return for new business. This obviously puts your treasury at risk, but it can also be considered bribery and end in a jail sentence.
Another very obvious way is to invite your customers to conferences and pay for the travel. Your local CEO might think this is ok because the travel is organized by a third party. IF this is the case, get him to speak to Smith Kline Beecham’s ex-China CEO for some advice.
What about if your agent deals with the customer. Just make sure you are not paying that agent unreasonable amounts and that the contract specifies that the agent is not allowed to bribe the customer!
These practices are hard for you to see if you are working in a large company with a lot of data in your SAP system. That is why we have created a platform of 300 must-have controls for SAP in order to help you quickly look at the main indicators that could point to some “special” activity.
Click below to download our free eBook and we can guarantee it will help you become a recognised leader by starting the transformation of internal control and internal audit!