Transparency International Publishes New Guidance To Counter Small Bribes
In June 2014, Transparency International published new guidance on countering small bribes, including "facilitation payments". Countering small bribes can be exceptionally challenging to companies, according to TI, because payments of these bribes are often entrenched and pervasive, and may be hard for management to detect. Although a number of countries, most notably the US, allow facilitation payments abroad, in most countries these payments and other small bribes are illegal. As such, these bribes must be addressed as a company faces legal risk, reputational damage and operational impact. To avoid or decrease exposure, companies should commit to a culture of integrity and prohibition of small bribes, and should implement programmes to counter small bribes
In its newly published guidance on countering small bribes, Transparency InternationaI UK (TI) provides ten principles on which companies may base their effective countering of small bribes. These principles include having a "supporting culture of integrity" at the company and committing to a policy that prohibits small bribes. Other principles cover the need for the implementation of a programme that counters small bribes, which includes effective risk assessment, training employees, addressing third party risks and monitoring the effectiveness of the programme. TI's final principle covers the company's responsibility to act strategically to influence the corrupt environment in which it operates.
Although the illegality of small bribes is nothing new, the impact of small bribes and the corresponding climate of corruption generally receive less attention than incidents which may involve large, one-off payments. But small bribery is generally just as unlawful and may equally put a company and its employees at...
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