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In brief: South African subsidiaries are asked to complete ABC training because a corrupt payment made locally can expose the group to prosecution abroad and, since April 2024, at home. Under the UK Bribery Act and South Africa’s PRECCA Section 34A, a business can defend itself only by showing it had adequate procedures to prevent bribery, and training records are central to that proof.
To employees of a South African subsidiary, an instruction from head office to complete ABC training can look like another administrative exercise.
Behind it sits a real legal risk. A questionable payment by an employee, agent or intermediary in South Africa can create criminal liability for the group abroad and, since April 2024, for the business here. Compliance teams need to know not only that anti-corruption policies exist, but that the people representing the business understand what those policies mean in practice.
Three laws drive this:
Whether a business is headquartered in London, New York or Johannesburg, a policy sitting on an intranet is not enough. The risk arises locally, for instance when a supplier offers an employee an improper incentive, or when an agent suggests an unofficial payment to speed up a government approval. The business needs confidence that its people will recognise these moments and know what to do next.
Regulators in all three jurisdictions treat training as central to an effective programme:
For compliance teams, training does two things. It helps employees spot red flags around gifts, hospitality, facilitation payments and third parties. It also ensures the same baseline expectations reach every country and business unit.
Head offices often ask South African subsidiaries for completion reports, assessment scores and policy acknowledgements.
Boards and chief compliance officers cannot oversee every interaction across the group, so they depend on evidence they can rely on to see whether standards are reaching the workforce and where gaps remain.
Of course, completing an e-learning module does not guarantee that someone will never pay a bribe, and it does not eliminate risk, but it does provide an honest, auditable record that the business took deliberate steps to communicate its expectations.
A training instruction from head office is best treated as a genuine risk control, not a box to tick.
Neither the UK Bribery Act nor PRECCA Section 34A requires the same annual course for every employee. Effective programmes are proportionate:
The training may take an hour. The record it leaves may be what the business relies on if something goes wrong.
Sarah Lovemore Roux is CEO of Compliance Online. She writes about how organisations can make complicated compliance questions understandable, practical and relevant to the way people work.
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