This document summarizes the key findings of a global fraud survey regarding Belgium: - Belgian businesses perceive low levels of bribery domestically but higher justification of unethical behaviors like cash payments compared to peers. Anti-bribery training is also lower. - Belgian companies emphasize external auditing for compliance and widely use third party monitoring systems. - Respondents believe the authorities are willing to prosecute corruption but support increased regulatory supervision. - Views are mixed on management cutting corners in tough times and board oversight of fraud risks. Support for whistleblowing incentives is also limited in Belgium relative to global averages.

1. Growing Beyond: a place for
integrity
12th Global Fraud Survey findings for Belgium
May 2012

2. Survey approach and participant profile
► Between November 2011 and February 2012, our researchers conducted a total of 1,758 interviews with employees
in 43 countries covering North America, Latin America, Europe, Africa, Middle East, Far East and Oceania.
► A sample of the largest companies in each country by turnover was interviewed. Senior executives interviewed
included CFOs, heads of internal audit, heads of legal and chief compliance officers. Details of the full survey are
shown below.
Role within organization % of respondents Global revenues % of respondents
Finance 42 Above US$1b 32
Internal Audit and Risk 22 US$500m – US$1b 22
Legal 9 Less than US$500m 46
Compliance 3
Other executives 24
► All interviews were conducted by telephone in the local language.
► 50 interviews were conducted in Belgium.
► Results are compared with findings for Western Europe, based on 602 interview across 12 countries - Austria,
Belgium, France, Germany, Greece, Italy, Netherlands, Norway, Spain, Sweden, Switzerland, and UK.
► Please note that, due to rounding, some figures may not sum to 100%. On some slides the “don‟t know” and "refused"
percentages have been omitted to allow better comparison between the given responses. As a result, percentages
may not total 100%.
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3. Summary for Belgium
► Belgian businesses perceive incidence of bribery and corruption in their country as very low (10%),
less than half that seen in Western Europe (22%) and significantly lower than the rest of world
(39%).
► Surprisingly, however, justifying unethical behavior, such as „making cash payments‟ (34%)
during an economic downturn, are at significantly higher levels than that of Western Europe
and globally.
► Belgian businesses support a broad range of anti-bribery policy measures, albeit below regional and
global levels. Notably, levels of available „training on anti-bribery/corruption policies‟ (38%) are far
below Western Europe (56%) and globally (55%).
► Belgian companies place strong emphasis on external auditing (82%) to monitor compliance with
anti-bribery laws, higher than Western Europe (73%) and the rest of the world (75%).
► Interestingly, „specialist monitoring software / IT systems‟ are also more widely employed than
the global or regional norm.
► Belgian businesses are more inclined to adopt processes and systems to manage and monitor third
party relationships than the rest of the world.
► In particular, over three-quarters (76%) use approved supplier databases, significantly
outpacing all comparatives.
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4. Summary for Belgium (cont’d)
► Similarly to both regional (61%) and global (63%) averages, respondents are likely (64%) to accept
that market entry presents new risks.
► Nearly 40% of Belgian companies believe liability is shared with third parties, slightly higher than
that of Western Europe (34%), but in line with the global average (39%).
► Less than a quarter (24%) support establishing whistleblowing compensation schemes, lower than
the region (38%) as a whole, and markedly below the global comparative (52%).
► The overall perception of Belgian authorities‟ willingness to prosecute bribery and corruption cases
(98%), and their perceived effectiveness at securing convictions (40%), is overwhelmingly positive.
These are considerably higher than both regional and global norms.
► The majority of Belgian companies (62%) mimic the regional (61%) outlook, in their support for
increased regulatory supervision, although this is slightly below the rest of the world viewpoint
(69%).
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5. Bribery and corruption is widespread
% Applies to
% Does not apply to % Applies to Western
Europe Global
Bribery/corrupt practices happen
82 10 22 39
widely in business in this country
In our sector, it is common
practice to use bribery to win 92 6 5 12
contracts
Bribery/corrupt practices have
increased because of the 76 12 16 24
economic downturn
Q: For each of the following, can you tell me whether you think it applies, or does not apply, to your country/industry, or
whether you don‟t know?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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6. Increased willingness to pay bribes or
misstate financial statements
Western
Europe Global
Entertainment to win/retain
42 26 30
business
Cash payments to win/retain
34 11 15
business
Personal gifts to win/retain
12 12 16
business
Misstating company's
10 5 5
financial performance
None of these 34 59 53
Don't know/refused - 3
Shown: percent stating response
Q: Which, if any, of the following do you feel can be justified if they help a business survive an economic downturn?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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7. Failure to follow through on tone from the
top
% Applies to
% Does not apply to % Applies to Western
Europe Global
We have an anti-bribery/anti-corruption
policy and code of conduct 22 78 84 81
Senior management has strongly
communicated its commitment to our anti- 28 72 84 84
bribery/anti-corruption policies
The guidance on anti-bribery/anti-
corruption is available in local languages 32 68 67 63
There are clear penalties for breaking our
anti-bribery/anti-corruption policies 38 60 71 71
People have been penalized for breaching
our anti-bribery/anti-corruption policies 44 54 40 45
There is training on our anti-bribery/anti-
corruption policies 62 38 56 55
Q: For each of the following, please tell me whether it applies, or does not apply, to your organiztion, or whether you
don‟t know?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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8. Types of compliance monitoring processes
in use
Western
Europe Global
Regular audits by external
82 73 75
auditor
Regular internal audits 78 84 86
Specialist monitoring
56 36 43
software/IT systems
Whistleblowing hotlines 40 49 53
Regular reviews by external
law firms or specialist 28 25 33
consultants
Shown: percent applies to
Q: Which of the following systems or processes does your organiztion have for monitoring compliance with anti-bribery
and anti-corruption laws?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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9. Inconsistent level of recognition of the risks
of investing in new markets
% Strongly disagree % Tend to disagree % Tend to agree % Strongly agree
Belgium 4 16 32 32
Western Europe
9 12 33 28
Global 7 13 36 27
Q: To what extent do you agree or disagree with each of the following statement? Planned investment by my company in
new markets will open us up to new risks
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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10. Approaches adopted in managing third party
relationships
Western
Europe Global
Approved supplier database 76 52 59
Background checking system 60 51 56
Audit rights / regular audits of
56 46 45
the 3rd party
Use external provider to run
48 28 34
checks
Check on ownership of the
48 48 50
3rd party
Use software/technology
40 27 30
based check of 3rd party
Shown: percent applies to
Q: Thinking about third parties that your organiztion uses, what systems or processes do you have in place to manage
and monitor those relationships?
Base: all who use a third party Belgium (25), Western Europe (422), Global (1268)
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11. Frequency of conducting due diligence into
fraud and corruption risks
% Never % Not very frequently % Fairly frequently % Very frequently % Always
Pre-acquisition
Belgium 17 4 21 13 46
Belgium 09/10 Not surveyed
Western Europe 17 13 16 9 44
Global 17 14 14 11 43
Post-acquisition
Belgium 27 15 27 8 23
Belgium 09/10 Not surveyed
Western Europe 24 14 18 13 31
Global 26 15 17 12 29
Q: How frequently has your company conducted due-diligence into fraud and/or corruption-related risks before acquiring a
new business in the last two years? Base: acquirers in Belgium (24), Western Europe (327), Global (957) And how
frequently has your company conducted fraud and/or corruption related post-acquisition due diligence in the last two
years? Base: acquirers in Belgium (26), Western Europe (339), Global (1032)
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12. Likelihood of management cutting corners
% Strongly disagree % Tend to disagree % Tend to agree % Strongly agree
Belgium 10 14 38 32
Western Europe 20 16 31 22
Global 23 19 29 17
Q: To what extent do you agree or disagree with each of the following statement? Company management is likely to cut
corners to meet targets when economic times are tough
Base: all respondents in Belgium (50), Western Europe (552), Global (1403)
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13. Limited awareness of liability for third-party
actions
Western
Europe Global
The company and 3rd party have
joint liability for the actions of the 38 34 39
3rd party
The company is liable for the
6 21 16
action of its 3rd party agents
The 3rd party only is liable for its
4 12 14
own action
Not relevant/Don't know/ refused 52 33 32
Shown: percent applies to
Q: Many companies make use of third-party agents as part of their normal commercial activities, particularly around
sales and distribution. Which of the following is closest to your understanding of the liability companies have for the
actions of 3rd party agents acting on their behalf Base: all respondents in Belgium (50), Western Europe (602), Global
(1758)
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14. Boards would benefit from deeper
understanding
% Strongly disagree % Tend to disagree % Neither / nor % Tend to agree % Strongly agree
Belgium 17 17 10 38 17
Western Europe 20 30 11 20 18
Global 17 20 10 26 26
Q: To what extent to do you agree or disagree with each of the following statement? Our board needs a more detailed
understanding of the business if it is to be an effective safeguard against fraud, bribery and corrupt practices
Base: all C-suite Directors Belgium (29), Western Europe (262), Global (736)
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15. Support for whistleblower bounty schemes
Belgium Western Europe
2 12
18
6
24 26
18
22
20
Global
2
11
20 22
30
15
% Strongly support % Tend to support
% Neither support nor oppose % Tend to oppose 20 30
% Strongly oppose % Don't know
Q: To what extent would you support or oppose compensation schemes for whistleblowing being established in your
country?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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16. Perception of regulators and law
enforcement authorities
Belgium 40 58 2
Western Europe 29 56 10 6
Global 27 50 16 6
% They appear willing to prosecute cases of bribery/corruption & seem effective in securing convictions
% They appear willing to prosecute cases of bribery/corruption but do not seem effective in securing convictions
% They do not appear willing to prosecute cases of bribery/corruption
% Don't know
Q: Thinking about regulators and law enforcement authorities in your country, which of the following statements best
describes their approach to cases of bribery/corruption?
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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17. Support for more supervision by regulators
Belgium 26 12 62
Western Europe 25 13 61
Global 19 10 69
% Disagree % Neither/ nor % Agree
Q: To what extent to do you agree or disagree with each of the following statements? There should be more supervision
by regulators and government in the future, to try to reduce the risk of fraud, bribery and corruption.
Base: all respondents in Belgium (50), Western Europe (602), Global (1758)
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18. Participants – region and country
Number of interviews
Australia 50 Japan 50 North America 100
Canada 50
USA 50
Central & Eastern Europe 405 Latin America 176
Baltic States† 50 Argentina 25
Czech Republic 50 Brazil 50 Western Europe 602
Hungary 50 Chile 25 Austria 51
Poland 55 Colombia 26 Belgium 50
Romania 50 Mexico 50 France 50
Russia 50 Germany 50
Turkey 50 Greece 50
Middle East*, India, & Africa 225
Ukraine 50 Italy 50
India 50
Netherlands 50
Kenya 25
Norway 50
Far East 150 Middle East* 50
Spain 50
China (inc. Hong Kong) 50 Namibia 25
Sweden 50
Indonesia 25 Nigeria 25
Switzerland 51
Malaysia 25 South Africa 50
UK 50
Singapore 25
Vietnam 25
† Latvia, Lithuania, Estonia
Base: all respondents (1758) * UAE, Jordan
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19. Number of Belgium interviews: role, sector,
revenue
Job function Sector
Finance 30 Automotive 5
Internal Audit and Risk 9 Consumer products / retail / wholesale 11
Legal 4 Financial services 1
Compliance - Life sciences -
Manufacturing / chemicals 11
Other executives 7
Oil, gas, and mining 2
Power and utilities 3
Revenue
Professional firms and services 5
More than $1 billion 5
Real estate 4
$500 million to $1 billion 6
Technology, communications, and
3
Less than $500 million 51 entertainment
Other transportation 4
Other sectors 1
Base: all respondents in Belgium (50)
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20. Ernst & Young
Assurance | Tax | Transactions | Advisory Christophe Ballegeer
PR & Communication Manager
About Ernst & Young christophe.ballegeer@be.ey.com
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