This article was reprinted with permission from Transparency International.
Transparency International's new guidance for companies, 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. Transparency International research shows that, globally, more than 1 in 4 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.
The guidance 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:
- 10 principles for countering small bribes
- a section on assessing risk
- practical examples & 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 US FCPA Act
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