David Alexander: "There’s probably three things that companies should do, if they’re concerned about bribery, corruption or indeed fraud.  Firstly is they need to understand what the risks are.  They need to understand where their businesses could be susceptible to fraud and bribery and to understand what the level of risk might be within those areas.  Secondly they need to take leadership from the top.  So senior management needs to get involved and they need to demonstrate that they are taking these issues seriously.  And then finally at a minimum there needs to be a process of awareness, a training programme within the business.  The most likely person to detect fraud or to detect bribery is a fellow employee, it’s not management, it’s not the internal auditors, it’s not the external auditors.  And the reason why it’s the fellow employee is that he is there or she is there 365 days of the year and knows the business and knows what’s going on.  But what they don’t know and they don’t understand necessarily is the...of fraud.  So you need an awareness programme that brings peoples…that lets people understand what the symptoms are and what to do if they suspect and those symptoms."

David Alexander: "If you ignore the Bribery Act and do nothing, you’re undoubtedly taking a risk because you cannot predict and you do not know if bribes are being paid or are going to be paid in your business.  If they are, and if that’s established you can’t go back and reinvent the wheel.  You cannot put procedures in place after the fact and therefore defend yourself against this new element of the legislation which is the criminal offence of failure to prevent.  So we’re advising clients, they don’t have to go overboard on this, but we’re advising them to take a few preliminary steps that can demonstrate that they have thought about this and they have attempted to put some procedures in place to preventing to take bribery."

David Alexander: "Traditionally if you want to prevent fraud, the focus has always been on accounting controls.  And the idea is that the tighter the accounting controls the less fraud you’ll have.  Unfortunately my experience is that’s not the case, that you can,  if somebody’s sufficiently motivated and they can rationalise the way of their behaviour then despite the controls being tight, you could still suffer from fraud.  So if you’re going to prevent it you need to not only address the controls, but you need to look at some of the softer issues as well.  And I’ll give you an example of that.  Employee manuals or employee handbooks that talk about the conduct and the conduct expected of individuals within a company is a pretty standard document.  The importance of that from a fraud perspective is it’s tackling peoples’ ability to rationalise fraud, because what they’ll do is they’ll read that and they’ll think, right, I understand what the company’s policy is on fraud, I understand what my responsibilities are, and I understand what will happen to me if I cross the line, if I commit fraud.  And a good analogy there is when you go into a shop and you see a sign in the shop and it says ‘shoplifting is a theft, is a crime, we will prosecute’ and it’s the same principle in an employee manual.  It’s saying this is unacceptable behaviour, if you engage in this behaviour this is what you can expect.  And what it’s trying to do, it’s not trying to stop all potential fraudsters, but it’s trying to prick peoples’ conscience and stop a few of them.  And that as I said is an example of sort of not putting all your eggs in one basket, of actually making sure that yes, you have tight controls, but you also address some of these softer issues around rationalisation and around the motivation of the individual as well."