Don’t Sweat the Petty Stuff? The True Costs of Petty Corruption




Photo credit: World Bank

In many developing countries, petty corruption is rampant to the degree of being deemed “everyday,” “cultural,” or even “survival” corruption. Small, usually frequent payments most often paid to lower level officials, petty corruption can seem negligible to an economy in comparison to grand corruption or state capture cases. However, the cumulative impact of corruption is costly to education systems, health services, and the business environment. In a lecture to participants at the 2016 School on Integrity hosted by Transparency International Lithuania, Director of U4 Anti-Corruption Resource Centre Boris Divjak calculated the true costs of petty corruption on democratic, economic, and social institutions.

Where central and local governments fail to deliver on public goods and services, citizens are left to pay extra for basic services such as school education, health services, and legal processes such as registering and operating a business. In situations where the good or service is imperatively needed, paying a bribe, facilitation payment, tip, or however it may be construed, does seem like a survival mechanism.  Read More...

The Psychology of Corruption


A few hundred rupees for the government ambulance to get your sick grandmother to the hospital in time; some extra shillings to your local school administrator to ensure your child is admitted to the best school; and a couple dollars to appease the police officer so you are not late for your important meeting, each seem easy to rationalize. “Popular and policy accounts,” Dr. David Halpern, Chief Executive of the Behavioural Insights Team said in his statement in the U.K. Anti-Corruption Manifesto, “can often misread why people ‘cheat,’ and what might reduce this cheating. When viewing corruption by others, we often assume that it is driven by self-interest and done by inherently bad people.”

However, the study of behavioral economics and the psychology behind corruption tells a very different story. Most corrupt acts are not committed by those whom we would likely picture as bad people, certainly not with knowing the specific contexts and rationalization behind a corrupt act.  Read More...

Countering Corruption in Emerging Markets



Richard Bistrong CEO Front-Line Anti-Bribery LLC interviewed CIPE’s Frank Brown Value Chain and Anti-Corruption Program Team Leader in a two part series. In the second interview, Bistrong and Brown discuss how collective action by small and medium enterprises in emerging markets can ‘counter the corruption narrative.’ What are the political reasons why foreign leadership might embrace international anti-bribery norms? How can small to mid-sized companies in emerging markets organize the compliance function? How can collective action raise the ‘water level’ of compliance efforts in emerging markets to a serious critical mass?  Read More...

Instituting an Effective Compliance Program- Continued


In the fourth and final video of CIPE’s Anti-Corruption Compliance series explains the remaining steps for instituting an effective compliance program, continuing off of what was laid out in the third video. The animated video explores how a company can implement the following points:

  • monitor and audit the quality of the internal control system’s performance and how these tasks should be done by an internal or external entity;
  • create a sound, company-wide reporting system and a way to investigate and look into the reported concerns or issues;
  • develop a spelled out spectrum of disciplinary actions and consequences in the company’s policies and procedures and apply enforcement and discipline fairly and consistency;
  • use incentives to encourage people in the company to behave ethically;
  • And when a violation is discovered and investigated, think of how to improve the compliance system so something similar does not happen again.

Learn more about each of these points by watching the video hereRead More...

Considering ISO 37001


, ,

ISO certified pic

The new ISO 37001 standard on anti-bribery management systems is expected to be finalized later this year. In many respects, the standard brings the re-affirmation of global best practices in anti-corruption compliance that emerged through norms such as the OECD Convention on Combating Bribery or Department of Justice and Serious Fraud Office guidance on the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, respectively. At the same time, ISO 37001 is not likely to be a silver bullet to all the compliance challenges given its lack of clarity in focus on the existence of formal elements of a compliance program vs. its effective implementation, or the cost of certification that may be prohibitive for smaller companies.

William Marquardt, Director, and David Holley, Managing Director at the Berkeley Research Group, LLC (a private management consulting firm) analyze ISO 37001’s promise and limitations in a recent post on The FCPA Blog:  Read More...

‘Carrots’ for Countering Corruption in Emerging Markets


, , ,

Richard Bistrong CEO Front-Line Anti-Bribery LLC interviewed CIPE’s Frank Brown Value Chain and Anti-Corruption Program Team Leader in a two part series. In the first interview, Bistrong and Brown discuss incentives or ‘carrots’ for small and mid-sized enterprises to take action even in environments with pervasive corruption practices.  Incentives for addressing corruption include creating sustainable businesses, and attracting multi-national organizations. How can we utilize a ‘carrots over sticks’ approach, to create incentives for small to medium size businesses in emerging markets to embrace ethical and compliant business practices? How can we get smaller enterprises in frontier markets beyond a ‘box checking’ mentality by making anti-bribery compliance a ‘selling point’ ?  Read More...

Q&A with ABB Legal Counsel on Anti-Corruption Compliance


, , ,


CIPE’s Anna Kompanek Director of Multiregional Programs interviews Lisette van Eenennaam Group Legal Counsel Integrity, Vice President, ABB Asea Brown Boveri Ltd about anti-corruption compliance for international corporations.

What attracted you to the field of anti-corruption compliance?

I became interested in related topics quite early when I was in law school in the Netherlands and I chose to specialize in International and European law – specifically human rights. I had the opportunity to do an internship at a Dutch multinational company where I supported the drafting of their first anti-corruption policy. About a year later, for my Master Thesis, they asked me to research the United Nations draft norms on human rights for international corporations. To my slight surprise, my first job saw me at a corporate investigations company where I started as an investigations analyst. Corporate investigations was fun and exciting, and as a result I moved on to several jobs in the field of private and public fraud and corruption investigations.  Read More...

The Value of Business Process Management to Anti-Corruption Programs


Business Process Management Team at the Iraq Ministry of Agriculture

By Robert E. Ross, Managing Director of Global Enterprise Consulting

When you think of corruption, you may not think about process and key performance indicators as critically important. And yet, establishing the appropriate foundation and metrics is critical to unearthing and preventing corruption in public and private sector entities. Corruption sees no boundaries. The conflicts in Iraq, for example, and the constant struggles among political parties, religious factions, and governmental leaders have allowed corruption to expand unchecked and unchallenged. Numerous other countries face the same ongoing challenges, whether in a post-conflict state or functioning in a seemingly stable environment. Yet Non-Governmental Organizations (NGOs), concerned citizens, and ministry workers eagerly strive to address corruption and improve delivery of services by government ministries and agencies to citizens in all areas, especially health services, pharmaceutical distribution, and basic utilities. Combating unfairness, social inequities, waste, fraud, abuse, and poor service delivery are inherent in anti-corruption programs.  Read More...

Instituting an Effective Compliance Program

The third video of CIPE’s Anti-Corruption Compliance series looks into detail the initial steps for instituting an effective compliance program. The video explains how to implement the following points:

  • conduct a risk assessment for a company’s specific business unit, geographic location, or for the entire firm;
  • develop a code of conduct with anti-corruption and bribery as the foundation for all company policies & procedures;
  • build a sound compliance infrastructure with a strong corporate governance that sets the right tone from the top as well as a chief compliance and ethics officer who looks at compliance issues within companies;
  • and provide regular, on-going education and training services for management, staff and board members on important elements of compliance system.

Learn more about each of these points by watching the video here.

This video is part of CIPE’s video series that explores the basic elements of an anti-corruption compliance system. The content of the videos are based on CIPE’s Anti-Corruption Compliance Guidebook .  Read More...

A Plan for Integrating Local Partners into the Global Supply Chain


, ,


CIPE’s Frank Brown, Value Chain/Anti-Corruption Program Team Leader, offers strategies to help local firms in emerging markets navigate and implement anti-corruption international standards on The FCPA Blog. Brown explains that local firms in emerging markets are interested in joining international supply chains but often do not have adequate compliance practices in place to be selected by multinationals. See the full article hereRead More...