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Corruption of Bribery
Chapter 6 : Corruption in the “Carbon World”
21 CONCLUSIONS
This Chapter has attempted to set out the main risks in the “Carbon World”. They are massive
and increasing daily. There are so many ways that companies can become involved ranging from
the compliance sector ‐ as an LCP‐, to being a voluntary player, investor or banker, that it is
impossible to consider all of them here. But the principles of risk assessment, controls and
contingency planning, discussed in Chapters 7‐12 are relevant and provide a solid foundation.
In addition, the following points are worth emphasising in the context of the UK Bribery Act:
Do not even think about entering the “Carbon World” without fully assessing the
supposed benefits and the risks: and cataloguing the incoming, internal, competitive and
outgoing decisions that could be perverted by corruption
Carefully monitor competitive activity when subsidised by offset or other governmental
support
Take the greatest care over retaining prospectors, brokers and other intermediaries by
applying enhanced due diligence to high risk contexts
Ensure that all trading in credits (including pricing, contract and delivery terms) or project
financing is risk assessed, effectively controlled and audited
Make sure that key performance drivers and metrics (especially for compliance purposes,
CSR, project development and finance) do not encourage fraud and corruption
Make sure that carbon accounts are fully aligned with statutory accounting records and
that they are reconciled on a daily basis if necessary
Provide members of the CSR or Carbon Department (see page xx) with enhanced training
On offset projects, ensure that there are effective reporting of incident processes in
place, that measuring equipment is accurate (see page xx) and that Monitoring Reports
(see page xx) are mandated at predefined intervals to coincide with financial accounting
periods
And, finally, good luck! In the “Carbon World” you will need it. Finally, whatever you do, do not
forget to turn off that 60W light bulb. It could save the planet.
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the Carbon World for Gower.docx | CONCLUSIONS