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Driving Growth

Join the fight against bribery and corruption

By: Sandy Boucher

When bribery and corruption run rampant within governments, they greatly erode our social fabric—negatively impacting such things as the provision of services such as schools, roads and hospitals, standards of living and global climate change efforts. They are estimated to cost the global economy upwards of one trillion dollars per year.

Over the last four years, many countries have been working together to build upon those original 1999 commitments and create stronger anti-corruption and anti-bribery regulations—a step that has resulted in phenomenal progress worldwide. While this is definitely something to celebrate, there is still a lot of work to be done. While many large public corporations have taken the necessary steps, many private businesses in the middle market have not turned their attention to this issue, yet.

If you’re a private business owner, it’s time to implement anti-corruption and anti-bribery policies in your organization—if you haven’t already. Getting started doesn’t have to cost you big bucks either. Here are some affordable steps you can take to get the ball rolling.

Step 1: Conduct a risk assessment

The scope and details of the anti-corruption risk assessment you conduct depends on your company, industry and country, but essentially it should seek to uncover where, when and how your company deals with foreign officials overseas.

For example, whether you’re interacting with foreign officials to acquire permits or simply to pay your taxes, look carefully into these exchanges and determine whether your interactions are documented and transparent. If there are situations where your company has been paying for things in cash, in private or where third-party agents are involved, you may want to explore these further.

Step 2: Explore high risk areas

Certain activities are recognized as high risk, for example, if you give gifts to foreign officials, pay for their travel, donate to foreign charities or political parties, or hire third-party agents to handle your company’s government relations, you should ensure compliance with the new rules surrounding these activities.

For one thing, acceptable gifts to foreign officials should be limited to inexpensive items that are not intended to influence an official’s behaviour in any way—and these items should be given in a transparent manner . Some charities could be fronts controlled by foreign governments—so if you’re making a donation, take steps to ensure they are legitimate. Also, the use of third-party agents to deal with foreign governments on your behalf has proven to be the most risky approach there is.  Turning a blind eye to their actions will not protect you from prosecution. It’s up to you to ensure you’re retaining agents with legitimate expertise and no history of shady dealings.

Step 3: Build an affordable compliance program

There are plenty of affordable measures you can take to get in line with anti-corruption and anti-bribery legislation across the world—and most of them stem from setting the tone from the top. By taking the time to implement anti-corruption and anti-bribery policies and procedures within your company, establish a cost-effective whistleblower hotline (to allow employees to anonymously report violations of these policies), de-incentivize people from committing corrupt acts (e.g. eliminate sales targets) and incentivize people to behave ethically, you’re well on your way to meeting today’s requirements.

Regardless of your business’s size, you have a part to play in eliminating bribery and corruption across the world. 

The author is a Senior Investigator at Grant Thornton LLP Canada. Grant Thornton International Ltd. is a leading global business adviser that helps dynamic organizations unlock their potential for growth. Punongbayan & Araullo (P&A) is the Philippine member firm of Grant Thornton International Ltd. For inquiries, you may direct them to 988-2288 ext. 760 or visit our website at

As published in Philippine Daily Inquirer dated 18 April 2016