Building a culture of integrity and compliance

Overview of Part III

This part of the report consists of two chapters that identify further changes that could be enacted to bring Australia up to date with comparative countries systems and in doing so, signal that Australia is serious about combatting foreign bribery (and other forms of corruption).

It assesses the adequacy of the government's proposed initiatives and what more needs to be done in light of what has been examined and recommended in evidence to the inquiry and other consultations, including the Phase 4 OECD Report. In particular, it looks at ways that Australia can build a corporate culture of integrity and compliance.

It explores the use of the facilitation payment defence in Australia. In particular, it scrutinises its prevalence internationally and examines arguments to retain or abolish the defence within Australia's anti-bribery legislative framework.

It also evaluates the following options to further strengthen Australia's foreign bribery framework:

• the expansion of the register of beneficial ownership;
• a debarment model; and
• development of official guidance relating to compliance with Australia's foreign bribery laws and how to make a voluntary report of foreign bribery.

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