The COVID-19 pandemic has accelerated changes in how businesses approach corporate social responsibility. COVID has accelerated many processes, and corruption is not immune to its influence. Underneath the constant reporting on the virus and the headwind of lockdowns lies the ever-present challenge of global corruption, a systemic barrier to development.
John Blood, Chief Legal and Corporate Affairs Officer & Corporate Secretary, AB InBev
Even before the pandemic, the World Economic Forum estimates that the global economy loses $3.6 trillion to corruption annually. It’s easy to assume the figure will be even higher this year as public and private funds, unknown amounts of stimulus, and charity get diverted to pet projects and shell companies and away from frontline workers and those most impacted by this crisis.
One can hope that heightened focus on responsible business behavior illuminated by the pandemic lingers for more than a moment and brings increased attention to global corruption. The cause has not been without its champions—the U.S. government alone has accounted for over 400 enforcement actions under the Foreign Corrupt Practices Act and issued sanctions of more than $6 billion in policing global corruption. Similarly, the governments of China and Brazil have received well-deserved publicity for their respective efforts to improve transparency and prosecute transgressors. But few would think we have done enough as a society, let alone as corporate citizens, to end the scourge of global corruption.
AB InBev and the evolution of anti-corruption compliance
At AB InBev, we take compliance with the FCPA and anti-corruption laws seriously, but our commitment to doing things the right way goes beyond mere compliance with law. We view anti-corruption as a broader inhibitor and challenge for the communities where we work and operate. Over 90 percent of our value chain is local, so we drive value by working with communities to improve transparency across the engines of our growth. We are committed to striking the right balance—building an environmental, social and governance (ESG) strategy that drives a positive impact on both our communities and our bottom line. What benefits the world and your business are one in the same. Often, that means harnessing emerging technologies, and working with the right partners to collaborate for better solutions and more positive impact in the communities in which the business operates.
When SABMiller joined AB InBev in 2015, we had an opportunity to do just that. In the past, we’d taken a thorough, albeit analog, approach to welcoming new teams. We worked closely with auditors and lawyers to understand risk and potential red flags to ensure the company was operating under legal guidelines. But with recent innovations and our expansion to 25 new countries via SABMiller, we knew there had to be a better way of doing this. It was clear that the standard operating procedure was ready to be disrupted.
For us, disruption had a name: BrewRIGHT. We developed BrewRIGHT, a data analytics platform using artificial intelligence (AI) and machine learning to identify patterns in everyday transactions to allow us to predict and prevent corruption. We piloted our new ethics technology with SABMiller, and the results were undeniable. Through AI and machine learning, BrewRIGHT parsed through decentralized data enabling the compliance team to efficiently spot potential infractions and identify areas in need of stronger safeguards. Given SABMiller’s sprawling enterprise with decentralized operating units, BrewRIGHT helped the team make informed management decisions and put appropriate measures in place for ethical business operations. Fast-forward to today, BrewRIGHT is embedded across our more than 500 brands and operations in nearly 50 countries. But to find, monitor and eliminate corruption, fraud, and money laundering across the globe, we need help. That’s why we created the BrewRIGHT Consortium, a forum where we can demonstrate our technology, companies can share data-driven insights, and we can collaborate for better solutions.
A corporate stand against corruption is more than intra-company compliance—it is about being part of the community.
Corporate operations have significant influence over the livelihoods of local people, often creating or preventing economic opportunity that determines security and stability. It’s both an opportunity and responsibility to ensure our communities thrive by sharing best practices, technologies, and tools to crack down on unethical practices that harm the communities in which we live and work.
Responsible business practices cannot be an afterthought; rather, ethical business practices should be embraced as a core value, and critical component of competitive advantage and financial growth. They also cannot be achieved with only one actor alone. Compliance with anti-corruption law across a country is nearly impossible without partnerships across broader economic ecosystems. It cannot only be about each market participants’ set of policies, procedures, and execution—it also needs to involve engaging in the dynamic economic situation in each community where we operate and looking for ways to make a positive change.
The corporate and global trade landscape has never been more complex. And while technology in many respects has brought us together, it is an immense challenge to have visibility into the countless local interactions that our operations have with local stakeholders on a daily basis. Supply chains and global networks consist of vast and elaborate moving parts, with third party suppliers or partners serving as extensions of your brand, and business must make their ability to remain compliant equally as important.
That’s why we’ve laid the groundwork, so others don’t need to start from scratch.
Technology is opening up the opportunity to Brew the Right way.
First and foremost we are brewers, so when creating BrewRIGHT we needed to consult with different partners with expertise and perspectives beyond our own, such as Covington and EY, to create the best solution possible.
Existing in Microsoft’s Azure cloud using Salesforce interface, BrewRIGHT utilizes models to proactively identify risk before issues arise. The program assigns a risk-criteria based on a variety of factors including, for example, the political connections of a specific vendor and whether that relationship could raise bribery or other ethical concerns.
So now, instead of sifting through a plethora of paper records, reviewing findings, and then investigating an issue, compliance teams can use intelligence resources to identify those involved, while using BrewRIGHT to cross-reference those names against their vendor list and payment patterns.
As bad actors become more sophisticated in their tactics, one of the benefits of leveraging algorithm-based platforms such as BrewRIGHT is that the program becomes increasingly intelligent as more data is input, thereby adapting to the ever-evolving regulatory landscape. As more users access and work within the ecosystem, the system learns from their efforts, building a knowledge repository and becoming more advanced. In basic terms, the system learns and grows.
Looking into the future
And it’s about to get even smarter.
At the 2020 annual meeting of the World Economic Forum, AB InBev and Microsoft called on other CEOs and world leaders to join the first anti-corruption data analytics consortium, based on the BrewRIGHT platform.
The consortium will help participants better detect and protect against corruption, by making BrewRIGHT algorithms available on a distributed platform accessible to all members. Members can apply these algorithms to their own data sets and then provide feedback to the central structure, resulting in additional inputs from a collective of companies. This has the initial and obvious advantage of improving the operational performance of the analytics system for each organization. By combining insights, organizations can capitalize on the experience of their peers, and use it to streamline their own operations.
Consider an analogy to credit card fraud detection. Most people are now generally aware that credit cards screen spending behavior for fraud. Imagine if those algorithms were limited to each consumer only based on the fraud experience of that specific consumer. The algorithm would be very limited, catching only payment sequences that track specific events that you reported to the company, and not taking into account the vast amounts of reported behavior from others. This approach would undermine the algorithm’s effectiveness. Credit card systems work because of the combined data from trillions of transactions across millions of consumers. A consortium would unlock a similar radical improvement to compliance systems. The rule is simple: more data, better compliance, improved communities.
And it’s just the beginning. As the world expects more from the private sector, corporations must be good stewards in the areas and ways in which they operate. It starts with good values, responsible leadership, and ethical business practices. A consortium would allow organizations operating in an ecosystem to mutually validate members of their supply chains and ensure only vendors that operate with acceptable practices need apply. Consortium-based compliance would do more to address the core set of risk factors of an economy, and not merely rely on the incorrect assumption that corruption is the product of isolated bad actors.
Now is the time for global leaders to come together and commit to upholding ethical and compliant businesses practices. If you’re interested in joining the consortium, then connect or follow Matt Galvin at AB InBev on LinkedIn, and join our next open house discussion on how technology is changing compliance. The future is the compliance community working together to improve our communities. Join us as we make the future today.
About the Expert:
John Blood is AB InBev’s Chief Legal and Corporate Affairs Officer, as well as the company’s Corporate Secretary. John holds a bachelor’s degree from Amherst College and a law degree from the University of Michigan Law School. He joined AB InBev’s global legal team in 2009, focusing on mergers and acquisitions, compliance and corporate law. He then served as the head of legal and corporate affairs for the North America Zone and, most recently, as global General Counsel.