How to Comply In High-Risk Corruption Countries

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  1. A very helpful and thought provoking discussion – thank you.
    The progressively international reach of domestic legislation – in the UK most recently the Bribery Act 2010 – is a welcome incentive to directors and senior managers to address corruption issues seriously. The key difficulty for them at present is not knowing for certain what constitutes “adequate procedures” (the phrase used in this UK legislation).

    I completely agree that good documentation to record what the firm does is the key, along with awareness training for those personnel who are engaged in the dialogue in teh high-risk countries. Thoroughly documenting such efforts creates an evidential file which can be presented to any investigative authority if required. Creating such a file need not compromise company confidentiality, but contributions to it must not withold facts or statements, nor under-report on activities.

    One of the main dangers is not making someone in authority responsible for owning this monitoring file. The implications through personal accountability for non-compliance are too serious to allow it to be delegated.