In today’s hyper-connected business environment, reputational damage can crystallise within hours. Allegations of bribery or corruption—whether proven or not—can trigger regulatory scrutiny, investor withdrawal, and long-term erosion of brand value. Effective management of bribery and corruption risk begins with leadership, culture, and the clear articulation of ethical standards that extend beyond formal compliance.

OpusDatum was engaged to support a multinational energy provider operating in a high-risk jurisdiction to rebuild trust, strengthen governance, and embed a sustainable anti-bribery and corruption framework.

Our Client

Our client is a leading provider of power generation and industrial energy solutions across the Middle East and Asia, specialising in gas and diesel generators, industrial automation, and renewable energy projects. As a major participant in Pakistan’s energy sector, the organisation has partnered with global energy brands and delivered critical infrastructure and industrial programmes.

However, the company’s operations came under intense scrutiny following allegations of financial misconduct and improper business practices, raising significant concerns among international stakeholders, regulators, and commercial partners.

The Challenge

In late 2018, a Pakistani Joint Investigation Team identified that the client had facilitated money laundering linked to a former President and the Minister for Law and Justice. Approximately US$250 million in embezzled funds were routed through fake accounts, with the client implicated in 13 payments totalling more than US$800,000 to a politically exposed individual.

In response, the organisation formally committed to abstain from bribery and corruption. However, translating this commitment into practice proved challenging. Local business norms often treated facilitation payments as an unavoidable cost of doing business rather than a corrupt act. This mindset was openly acknowledged by employees and, critically, reinforced at board level.

The organisation faced a fundamental cultural and governance challenge: how to align global ethical expectations with entrenched local practices while operating in a high-risk regulatory environment.

Our Approach

OpusDatum was engaged to design and implement a comprehensive Anti-Bribery and Corruption (ABC) programme aligned with international best practice and tailored to the organisation’s geographic footprint.

We developed a new ABC policy and supporting Code of Conduct covering expected standards of behaviour, escalation and reporting procedures, conflicts of interest, gifts and hospitality, third-party engagement, whistleblowing, monitoring, and disciplinary consequences. The framework was designed to recognise cultural nuance without compromising ethical standards or legal obligations.

To address local risk exposure, we introduced a country-specific gifts and hospitality matrix, providing clear, proportionate thresholds aligned to local cost of living while eliminating ambiguity around acceptable conduct.

Embedding accountability was a central focus. We worked with senior management to implement a mandatory annual attestation process for all employees, regardless of seniority, confirming understanding of and adherence to the ABC policy. All materials were translated into relevant local languages to ensure accessibility and consistency.

To support oversight and sustainability, we recommended continuous monitoring through defined risk and performance indicators. A management dashboard was implemented to provide real-time visibility of bribery and corruption risks, enabling informed decision-making and timely intervention.

Comprehensive training was delivered across all locations, in both English and Urdu, reinforcing expectations, practical scenarios, and safe reporting mechanisms. The Code of Conduct included a dedicated section on raising concerns, supported by strengthened whistleblowing arrangements.

Key Benefits & Measurable Outcomes

The implementation of the ABC programme delivered tangible improvements in governance, culture, and risk management.

Enhanced Corporate Governance

Clear policies, defined accountability, and consistent enforcement strengthened internal controls and board-level oversight.

Cultural Alignment with Ethical Standards

By addressing local practices directly and transparently, the programme shifted perceptions of bribery from a business necessity to an unacceptable risk.

Strengthened Reputation and Stakeholder Confidence

Proactive remediation improved engagement with regulators, investors, and international partners, supporting the organisation’s continued participation in global supply chains.

Improved Risk Visibility

Real-time monitoring and reporting enabled senior management to identify emerging bribery and corruption risks and take corrective action promptly.

Consistent Global Standards

Multilingual policies and training ensured that ethical expectations were understood and applied consistently across jurisdictions.

Increased Employee Awareness and Engagement

Targeted training and clear reporting channels empowered employees to challenge misconduct and raise concerns without fear of retaliation.

Reduced Legal and Financial Exposure

Stronger controls materially reduced the organisation’s exposure to enforcement action, financial penalties, and reputational harm.

Strengthen Your Organisation’s Compliance Framework

Operating in high-risk markets demands more than policies on paper. It requires leadership commitment, cultural change, and robust governance.

If your organisation needs to strengthen its anti-bribery and corruption framework or respond to regulatory and reputational risk, OpusDatum can help.

Contact us today to discuss how we can support ethical, resilient, and compliant business operations.