CIPE_Anti-Corruption_Compliance_Guidebook - ANTI CORRUPTION COMPLIANCE A Guide for Mid-Sized Companies in Emerging Markets Center for International

CIPE_Anti-Corruption_Compliance_Guidebook - ANTI CORRUPTION...

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A Guide for Mid-Sized Companies in Emerging Markets Center for International Private Enterprise ANTI - CORRUPTION COMPLIANCE
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The Center for International Private Enterprise (CIPE) strengthens democracy around the globe through private enterprise and market-oriented reform. CIPE is one of the four core institutes of the National Endowment for Democracy and an affiliate of the U.S. Chamber of Commerce. Since 1983, CIPE has worked with business leaders, policymakers, and journalists to build the civic institutions vital to a democratic society. CIPE’s key program areas include anticorruption, advocacy, business associations, corporate governance, democratic governance, access to information, the informal sector and property rights, and women and youth. Disclaimer: This publication by the Center for International Private Enterprise (CIPE) provides general information related to anti-corruption compliance based on international best practices and is meant for informational purposes only. This publication does not provide legal advice of any kind and should not be used as a substitute for obtaining legal advice. Although CIPE has gone to great lengths to make sure the information in this guide is accurate, it cannot guarantee that the information is complete or up-to-date. CIPE strongly recommends that readers consult a licensed attorney if they require legal advice. Copyright © 2014 by the Center for International Private Enterprise All rights reserved Lead Author Anna Nadgrodkiewicz, Director, Multiregional Programs, CIPE Contributors Frank Brown, Value Chain/Anti-Corruption Program Team Leader, CIPE Certified Compliance and Ethics Professional-International (CCEP-I) Paul Kitson, Practitioner and consultant, former head of compliance at TNK-BP John Morrell, Senior Program Officer, Asia, CIPE Layout Anna Dawson, Communications Coordinator, CIPE Cover Design Jon Custer, Social Media Coordinator, CIPE
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Introduction 2 1. Overview of anti-corruption compliance 5 *What does compliance mean? 5 *What is anti-corruption compliance? 6 *Why is anti-corruption compliance important for mid-sized businesses? 12 2. Anti-corruption compliance in mid-sized companies 18 *What are multinational corporations expecting from their business partners? 18 *Where to start? Risk assessment and management 20 *Good corporate governance 23 3. Designing and implementing a compliance program 26 *Standards of conduct/policies and procedures 27 *Compliance oversight, commitment and resources 29 *Education and training 33 *Monitoring and auditing 36 *Reporting and investigating 39 *Enforcement, discipline, and incentives 43 *Response, prevention, and improvement 46 4. Transition to a clean enterprise 47 Resources and bibliography 50 Anti-Corruption Compliance: A Guide for Mid-Sized Companies in Emerging Markets
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Anti-Corruption Compliance
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A Guide for Mid-Sized Companies in Emerging Markets Center for International Private Enterprise 1 “Improved compliance reduces risk, and reducing risk reduces costs. This guidebook is a valuable resource
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