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