How do you find out whether there is any truth to the claim that an employee is receiving kickbacks from a supplier? Investigating kickback allegations is not easy, for many reasons:
» Direct evidence of the transaction is not typically documented in the company’s accounting books and payment records;
» Suppliers’ accounting books and records are not generally made available to their clients unless it is a key supplier or the contract includes a broad audit clause;
» Large companies usually have hundreds,if not thousands, of vendors, so it is difficult to pinpoint which one(s) may be providing kickback payments;
» A vague allegation will not be investigated by law enforcement agencies so it is imperative to conduct an internal investigation to obtain sufficient evidence in order to make a compelling case.
Such investigations must be undertaken to stop financial leakage and to minimize exposure to the UK Bribery Act and other applicable anti-corruption legislation that imposes liability for receiving bribers in the private sector