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Anti-Corruption Compliance

A Guide for Small and Mid-Sized Organizations

Gemma Aiolfi

This indispensible book offers step-by-step guidance to small and mid-sized companies and non-profit organizations in managing corruption risks in overseas markets. It covers how and why to build a culture of integrity, develop a risk-based anti-corruption compliance programme, and engage with other industry players in collective action against shared corruption challenges, taking a hands-on approach and featuring case studies, quick definitions, tips and practical tools such as checklists.
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Gemma Aiolfi

This introduction to anti-corruption compliance recognizes the challenges that SMEs face in developing compliance programmes to protect themselves from corruption-related risks in overseas markets. The main challenges are limited resources, the need for a highly tailored, risk-based approach and the fact that most official guidance is written with large organizations in mind. It offers reassurance that anti-corruption compliance is not a headache but an opportunity to building a strong and sustainable base for the organization to flourish.

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Gemma Aiolfi

This chapter answers the question: why does my organization need to care about anti-corruption compliance? It covers the changing business environment and the legal risks to which all companies and non-profit organizations worldwide – including SMEs – are increasingly exposed. It also looks at growing pressures on SMEs from larger customers and investors to demonstrate compliance systems. Ultimately, it demonstrates the benefits of building compliance into daily business, covering due diligence, access to investment, peace of mind, reputation and recruitment.

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Gemma Aiolfi

This chapter sets out three concepts crucial to the success of an anti-corruption compliance programme: culture, leadership and governance. It offers practical advice on how to build the type of organizational culture in which acting with integrity is part of daily business and speaking up is encouraged. Leadership is key to this process, as it reflects the values that drive behaviours at all levels. The chapter also addresses governance considerations that are essential to promoting compliance and providing the backbone for effective leadership.

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Gemma Aiolfi

A risk assessment is the basis of a robust anti-corruption compliance programme that addresses an organization’s specific risks and allows managers to prioritize limited resources. It examines relevant official guidance and sets out the compelling reasons for conducting a risk assessment. It then takes readers step-by-step through the process of carrying out a risk assessment, covering the main elements of planning the process, identifying and evaluating the risks, and assessing the effectiveness of current controls.

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Gemma Aiolfi

This chapter guides readers in developing the essential elements of an anti-corruption compliance programme that effectively addresses the identified risks. It introduces the benefits of a code of conduct and how to draft one, then widens the view to explore anti-corruption policies and procedures that SMEs may need to consider. These include policies on anti-bribery, gifts and entertainment, political and charitable donations, conflicts of interest and dealing with bribery risks from third parties. The chapter ends with advice on implementing financial controls to manage not only bribery risks but other financial crimes such as fraud and theft.

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Gemma Aiolfi

Is it ever acceptable to pay a bribe? Are facilitation payments bribes? What are some approaches to training and awareness-raising? This chapter deals with these questions and others that commonly arise when a small or mid-size organization develops an anti-corruption compliance programme with its staff. Among other things, it offers practical advice on stopping facilitation payments, whether and how to set up an advice or whistleblowing hotline, compliance monitoring mechanisms and what to do in a corruption-related crisis.

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Gemma Aiolfi

Widening the view to corruption risks across entire markets and industry sectors, this chapter offers insights into how SMEs can tackle corruption risks more effectively by joining forces with other concerned companies and organizations. Specifically, it looks at the growing popularity and success of collective action aimed at solving common corruption challenges and raising standards of integrity in specific business sectors and geographical areas.

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Determann’s Field Guide to Data Privacy Law

International Corporate Compliance, Third Edition

Lothar Determann

Companies, lawyers, privacy officers and marketing and IT professionals are increasingly facing privacy issues. While information is freely available, it can be difficult to grasp a problem quickly, without getting lost in details and advocacy. This is where Determann’s Field Guide to Data Privacy Law comes into its own – identifying key issues and providing concise practical guidance for an increasingly complex field shaped by rapid change in international laws, technology and society.
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Starting a compliance program

International Corporate Compliance, Third Edition

Lothar Determann