Building a culture of integrity: practical approaches to anti bribery and corruption for general managers

Understanding the risks of bribery and corruption in entrepreneurship

Why bribery and corruption are real threats for entrepreneurial ventures

Bribery and corruption are not just issues for large multinational corporations. Startups and growing businesses face significant risks, especially when operating in foreign markets or dealing with government officials. The pressure to win contracts, secure permits, or speed up processes can make unethical shortcuts tempting. However, these actions expose your business to legal, financial, and reputational damage.

Key risk areas for general managers

• Third parties: Engaging agents, consultants, or distributors can increase exposure to bribery risks, especially if due diligence is limited.
• Government interactions: Dealing with public officials or foreign officials, even for routine business, can trigger compliance obligations under laws like the FCPA (Foreign Corrupt Practices Act) and other international anti bribery laws.
• International operations: Expanding into a foreign country often means navigating different legal frameworks and cultural norms around gifts, hospitality, and facilitation payments.
• Procurement and supply chain: Corruption risks can arise when selecting suppliers or negotiating contracts, particularly if policies and procedures are unclear.

Understanding the impact of enforcement and global standards

Enforcement actions by authorities in the United States and other countries are increasing. The United Nations Global Compact and similar initiatives are pushing for higher standards in anti corruption and compliance. Failing to implement effective risk management can result in heavy fines, loss of business opportunities, and even criminal charges for individuals and companies.

Embedding integrity into your business culture

Building a culture that actively resists bribery and corruption starts with awareness. General managers must recognize that anti bribery policies and risk management are not just legal requirements—they are essential for sustainable growth and trust. For more on how strong values shape business success, see this resource on building a thriving team culture in entrepreneurship.

Creating clear anti bribery and corruption policies

Defining Expectations and Setting the Tone from the Top

For general managers, establishing a robust anti bribery and corruption (ABC) policy is not just a compliance exercise—it is a foundation for ethical business. A clear policy signals to employees, third parties, and government officials that your organization is committed to integrity, whether operating locally or in a foreign country. The policy should outline what constitutes bribery, including payments to public officials, facilitation payments, gifts, and hospitality, and make explicit reference to relevant bribery laws such as the Foreign Corrupt Practices Act (FCPA) and international frameworks like the United Nations Global Compact.

Key Elements of Effective Policies and Procedures

• Scope and Applicability: Define who the policy covers, including employees, third parties, agents, and contractors. Make it clear that the policy applies in every market, including foreign operations and dealings with foreign officials.
• Prohibited Conduct: List prohibited actions, such as offering, promising, or giving anything of value to public officials or business partners to gain an improper advantage. Highlight risks associated with third party intermediaries and government officials.
• Gifts, Hospitality, and Donations: Set thresholds and approval processes for gifts, entertainment, and charitable contributions, especially when dealing with public officials or foreign government representatives.
• Due Diligence and Risk Management: Require due diligence on third parties, including limited scope reviews for low-risk partners and enhanced checks for higher-risk relationships. This helps counter bribery and corruption risks before they materialize.
• Reporting and Enforcement: Outline procedures for reporting suspected violations and the consequences of non-compliance. Make clear that enforcement actions will be taken against breaches, regardless of the individual’s position.

Aligning with Global Standards and Local Laws

Policies must be tailored to reflect both international anti bribery standards and local laws in each country of operation. For example, the FCPA in the United States prohibits bribery of foreign officials, while other jurisdictions may have stricter or broader requirements. Regularly review and update your policies to keep pace with evolving enforcement actions and regulatory expectations.

Embedding Policy into Company Culture

Policies are only effective if they are understood and embraced by everyone in the organization. Integrate anti bribery and corruption principles into your company’s values and daily operations. This includes communicating policies clearly, providing accessible resources, and making compliance part of performance evaluations. For more on fostering a strong team culture that supports ethical behavior, see building a thriving team culture in entrepreneurship.

Practical Steps for General Managers

• Draft and circulate a comprehensive ABC policy, referencing relevant laws and standards.
• Ensure all employees and third parties acknowledge and understand the policy.
• Review and test policies regularly to address new risks, including those arising from international expansion or changes in business partners.
• Document all policy updates and training sessions for audit and enforcement purposes.

Training teams to recognize and resist unethical practices

Empowering Teams to Identify and Resist Corruption

Building a strong anti bribery and corruption (ABC) culture starts with equipping your team to recognize and resist unethical practices. Even the most robust policies and procedures can fall short if employees are not confident in spotting bribery risks or understanding their responsibilities under anti corruption laws, including the Foreign Corrupt Practices Act (FCPA) and other international regulations.

• Practical, scenario-based training: Go beyond theory. Use real-world examples relevant to your business, such as interactions with government officials or third parties in a foreign country. This helps teams internalize what bribery and corruption look like in daily operations.
• Clear communication of policies: Ensure all employees, including limited-term staff and those in high-risk roles, understand your anti bribery policy. Regularly update training to reflect changes in laws, enforcement actions, and global standards like the UN Global Compact.
• Role-specific guidance: Tailor training for employees who interact with public officials, manage third party relationships, or operate in regions with higher bribery risk. Highlight the importance of due diligence and compliance with both local and international bribery laws.
• Encourage open dialogue: Create an environment where employees feel comfortable raising questions about potential corruption risks or policy ambiguities. This supports early detection and risk management.

Embedding Compliance in Everyday Business

Training is not a one-off event. It should be part of a continuous effort to reinforce your company’s commitment to countering bribery and corruption. Consider integrating compliance reminders into regular meetings, onboarding, and performance reviews. This keeps anti bribery and anti corruption top of mind for everyone, from frontline staff to senior management. A strong training program also supports your broader compliance framework. For more on how effective compliance programs drive entrepreneurial success, see this in-depth look at the true purpose of corporate compliance programs. By investing in ongoing education and open communication, general managers can help teams confidently navigate the complex landscape of bribery corruption risks, whether dealing with public officials, third parties, or operating in a foreign market.

Establishing transparent reporting and whistleblowing channels

Encouraging Openness and Accountability

Building a culture where employees feel safe to report suspected bribery or corruption is essential for effective anti bribery and anti corruption (ABC) compliance. General managers should foster an environment where transparency is valued and retaliation is strictly prohibited. This means communicating clearly that everyone, from junior staff to senior management, is responsible for upholding policies and procedures related to bribery laws and corrupt practices.

Designing Accessible Reporting Channels

A robust reporting system should be easy to access and use, even for employees in foreign countries or remote locations. Consider multiple channels, including limited anonymous hotlines, digital platforms, and direct lines to compliance officers. Make sure these options are well publicized and available in relevant languages, especially if your business operates internationally or deals with third parties and government officials in different jurisdictions.

• Anonymous hotlines for confidential reporting
• Email or web-based forms for written concerns
• Direct access to compliance teams for urgent issues

Protecting Whistleblowers and Ensuring Follow-Up

Employees must trust that their concerns about bribery, corruption, or violations of the Foreign Corrupt Practices Act (FCPA) will be taken seriously. Implement clear anti retaliation policies and communicate them regularly. Ensure that all reports, whether involving public officials, third parties, or internal staff, are investigated promptly and impartially. Document outcomes and share learnings across the organization, while respecting confidentiality.

Integrating Reporting with Risk Management

Reporting channels should not operate in isolation. Integrate them into your broader risk management framework to identify trends, spot vulnerabilities, and improve your anti bribery and anti corruption program. Regularly review data from whistleblowing channels to inform updates to your ABC policy, training, and third party due diligence processes. This approach aligns with international standards, including the United Nations Global Compact, and supports compliance with local and foreign bribery laws.

Key Takeaways for General Managers

• Promote a speak-up culture where employees are empowered to report concerns about bribery and corruption
• Offer accessible, confidential, and multilingual reporting options for all staff and third parties
• Protect whistleblowers and ensure transparent follow-up on all reports
• Use reporting data to strengthen your anti bribery and anti corruption policies and procedures

Managing third-party risks and due diligence

Why third-party relationships matter in anti-bribery efforts

Third parties—such as suppliers, agents, consultants, and joint venture partners—can expose your business to significant bribery and corruption risks. Many enforcement actions under the Foreign Corrupt Practices Act (FCPA) and similar international bribery laws have involved payments made through intermediaries. These risks are heightened when operating in a foreign country or dealing with government officials and public officials.

Key steps for managing third-party risks

• Due diligence: Before engaging any third party, conduct thorough background checks. This includes reviewing their ownership, reputation, and past involvement in bribery or corrupt practices. Use public records, compliance databases, and, where possible, independent verification.
• Risk assessment: Evaluate the level of risk each third party poses. Factors include the country of operation, the nature of the business relationship, and any interactions with government or public officials.
• Written agreements: Ensure all third-party contracts include clear anti-bribery and anti-corruption (ABC) clauses. These should reference your company’s policies and procedures, as well as compliance with local and international laws, including the FCPA and the United Nations Global Compact principles.
• Ongoing monitoring: Regularly review third-party activities for signs of bribery or corruption. This can involve audits, transaction reviews, and periodic re-assessment of risk.
• Training and communication: Provide third parties with access to your anti-bribery policy and offer training on compliance expectations. Make it clear that your business has zero tolerance for bribery, including limited exceptions only where permitted by law.

Integrating third-party risk management into your compliance program

Effective risk management means embedding third-party oversight into your broader compliance framework. This includes aligning your policies procedures with international standards and ensuring that all parties—internal and external—understand their responsibilities. When incidents occur, swift investigation and corrective action are essential to maintain trust and demonstrate your commitment to countering bribery and corruption.

By proactively managing third-party risks, general managers can protect their business from legal exposure, reputational damage, and financial loss. This approach not only supports compliance with global anti-bribery laws but also strengthens the culture of integrity across your organization.

Responding to incidents and learning from mistakes

Effective Incident Response: Steps and Best Practices

When bribery or corruption incidents occur, a prompt and structured response is essential for maintaining trust and compliance. General managers must ensure that their organizations are prepared to handle such situations with clarity and professionalism.

• Immediate containment: Quickly assess the scope of the incident. Secure relevant documents and data, and prevent further actions that could escalate the risk or violate anti bribery laws.
• Internal investigation: Launch a thorough and impartial review, following established policies procedures. This should involve compliance teams and, if necessary, external experts to ensure objectivity and adherence to international standards like the FCPA and the UK Bribery Act.
• Engagement with authorities: If the incident involves public officials, government officials, or foreign officials, it may be necessary to notify law enforcement or regulatory bodies. Understanding local and international bribery laws is crucial, especially when operating in a foreign country or dealing with third parties.
• Transparent communication: Keep stakeholders, including employees, business partners, and, where appropriate, the public, informed about the situation and the steps being taken. This transparency reinforces your commitment to anti corruption and the Global Compact principles.
• Remediation and disciplinary action: Apply corrective measures, which may include updating policies, retraining staff, or taking disciplinary action against those involved. Ensure that your anti bribery and corruption policy is robust enough to address gaps revealed by the incident.

Learning and Continuous Improvement

Every incident, whether involving a third party or internal personnel, offers valuable lessons. General managers should prioritize risk management by:

• Reviewing and strengthening anti bribery and anti corruption policies based on findings.
• Enhancing due diligence processes for third parties and foreign business partners.
• Updating training programs to address new risks or trends in corrupt practices.
• Encouraging a culture where reporting concerns about bribery corruption is safe and supported.

By systematically responding to incidents and integrating lessons learned, organizations can build resilience against future enforcement actions and foster a culture of integrity that meets both local and international compliance expectations, including limited exposure to risks associated with third party relationships.