A Guide for Mid-Sized Companies in Emerging Markets
Center for
International
Private
Enterprise
ANTI
-
CORRUPTION
COMPLIANCE
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
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
Anti-Corruption Compliance
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
