Countering Small Bribes is the title of guidance from TI-UK. It’s a 46-page document from Transparency International, the international anti-corruption pressure group, to help businesses avoid facilitation payments and other small bribes.
Countering Small Bribes: Principles and good practice guidance for dealing with small bribes including facilitation payments provides practical advice on addressing the challenge of countering small bribes including “grease payments”. It is also designed to be of assistance to regulators, law-makers, prosecuting agencies and professional advisers.
Countering small bribes is a complex challenge for companies, says TI UK. Transparency International research shows that, globally, more than one in four people paid a bribe in a recent 12 month period, highlighting the scale of the problem facing companies. Demands most often occur in overseas markets, where employees may be vulnerable through travelling alone; or, the company needs to release critical goods from customs.
So how do you meet the challenge?!The guidance speaks in terms of ‘ensuring a supporting corporate culture’, committing to eliminating small bribes,and assessing the risks of making such payments; communicating to and training staff, preventing the bribes being made, and doing internal accounting, and preparing to manage incidents that do happen. And always monitor and evaluate what you are doing. Also offered is a checklist and ‘red flags’ to watch out for. More practically, ways may range from encouraging public or private bodies to publish their rules and charges, to remove uncertainty that corrupt officials and vested interests can exploit; to firms sharing their experiences, or encouraging automation to remove officials from processes.
Case studies are also offered, such as the Maritime Anti-Corruption Network’s work in Nigeria.
The guidance by Peter Wilkinson and edited by Robert Barrington and Nick Maxwell provides a set of principles, discussion and advice designed to help companies operate to high ethical standards, protect their reputations and fulfil their legal obligations. It contains:
Ten principles for countering small bribes
A section on assessing risk
Practical examples and case studies
Model negotiation steps for resisting demands
A self-assessment checklist aligned to the ten Principles and good practice set out in the guidance
Information on the United States’ FCPA Act.
Visit http://www.transparency.org.uk/.
