Bribery and Corruption Top Area of Compliance Risk, According to New Consero Survey

Corporate Counsel: Compliance Chiefs Grappling With Resources, Risk
December 19, 2013
January 2014 General Counsel Report
January 1, 2014

Bribery and Corruption Top Area of Compliance Risk, According to New Consero Survey

BETHESDA, MD – (December 19, 2013) – One third (33%) of surveyed Chief Compliance Officers named bribery and corruption as the top area of current risk for their companies, according to a new survey by Consero Group, an international leader in creating high-level, invitation-only events for senior executives. The results were reported as part of the 2013 Corporate Compliance & Ethics Survey, compiled by Consero Group in partnership with The Red Flag Group.

In addition, nearly a third (29%) of survey respondents said they anticipate bribery and corruption will continue to be a future area of risk for their companies. More than half (58%) of survey participants said their third-party suppliers are not sufficiently focused on risk.

“Likely as a result of the enhancement and enforcement of U.S. and international laws, anti-corruption efforts lie at the heart of many compliance programs,” said Paul Mandell, Founder & CEO of Consero. “The data indicate that anti-corruption will continue to be a major focus in the year ahead and for years to come.”

Lack of Independent External Reviews of Compliance Programs

Just 16 percent of survey participants said they currently measure their compliance program’s performance via external consultant review, while 82 percent rely on internal departmental reviews, outside departmental reviews, self-assessment by CCO, or employee surveys. At the same time, the majority (60%) said self-directed compliance and ethics training was insufficiently effective.

“The survey indicates that a majority of CCOs do not pursue independent assessments of their compliance programs,” said Mandell. “Independent external reviews are essential, and they should happen at least annually to test the value of the compliance program and provide benchmarking against other programs within the industry.”

Other findings included:

  • Low Number of Compliance Officers per $100 Million: Sixty-five percent of survey participants said that their company has just one compliance team member for each $100 million in company revenue.
  • Integrating Compliance into Business Is Priority: Nearly half (44%) of the survey participants said their top compliance priority for the next 12 months is integrating compliance efforts into the business.
  • Hiring Practices Not Aligned with Compliance Objectives: Nearly half (46%) said their company’s hiring and performance evaluation criteria are not sufficiently aligned with the company’s compliance and ethics objectives.

The 2013 Corporate Compliance & Ethics Survey included questions that were posed to Fortune 1000 Chief Compliance Officers in connection with the invitation-only Corporate Compliance & Ethics Forum hosted by Consero in November 2013. A total of 52 responses were provided. 

About Consero

Founded in 2010, Consero Group is an international leader in creating industry-specific events for senior-level executives in industries that include: Legal, Compliance, Shared Services, Customer Experience, Finance, IT, HR, Procurement, among others. With operations in the U.S. and in Europe, Consero is best known for transforming the executive experience through intimate, invitation-only programs in a sophisticated learning environment with high-level content. For more information on Consero, please visit

About The Red Flag Group

Founded in 2006, The Red Flag Group is one of the world’s leading independent corporate governance and compliance firms with offices and research centers in the United States, Europe, Asia, Africa and Latin America. The Red Flag Group’s team of former in-house counsel and compliance officers, supplemented by a diverse team of forensic accountants and regulatory officials, provide thought leadership to major corporations worldwide and assist them in creating and maintaining customized and integrated compliance solutions that add value to their businesses. For more information on The Red Flag Group, please visit