| Accountability for everyone
Rather
than attempt to improve on a perfectly good explanation by the original
authors, here is an excerpt from the Transparency International paper:
"Transparency
International (TI) introduced the Business Principles for Countering
Bribery in 2002, primarily for large companies. Since then, the
Business Principles have become
recognised as a leading anti-bribery
standard and a model for anti-bribery programmes. An edition of
the Business Principles more relevant to small and medium sized
businesses
(SMEs) has now been developed, together with guidelines
which give practical advice to help those organisations with fewer
resources of time, money and people, through the
process of developing an anti-bribery strategy to suit their size and structure."
The
risks of engaging in bribery are obvious. It is illegal and
carries fines and even prison terms. Especially for small
businesses such a blow can be ruinous. For that reason most
people wouldn't expect a small business to engage in such
activities. But, as the saying goes, 'Trust is good.
Control is better.'
The advantages of having an accountability
program like the Business Principles for Countering Bribery in place
are obvious, as well. It increases that business' standing as an
ethically sound trader; those businesses who are not yet government
vendors stand better chances of becoming such; it is excellent
protection against legal penalties; and anyone paying or receiving
bribes will be discovered much more quickly.
The key trouble
spots that can lead to impropriety, or even the appearance of
impropriety, are contributions, conflicts of interest, gifts or
entertainment, or facilitation payments.
A contribution is
laudable but, in this day and age, certain precautions must be taken
lest the aim of this charity is called into question. Whether the
contribution goes to a charity or a political party, the donation
should always be made to an organization or a party rather than to an
individual. Absolutely avoid making donations to groups with whom
you expect to have business dealings in the near future.
Conflicts
of interest can be insidious. Often they're easy to spot and as
easy to avoid, but sometimes a previous relationship can exist of which
the decision makers are unaware. The best way to deal with such a
possibility is to have very clear and definite rules in place about how
such a situation will be handled, and to handle it immediately if it
does occur.
Gifts and entertainment are a very dicey
proposition. They are probably the best known method for
concealing bribes. Consequently, they are often illegal under
local laws. On the other hand, gifts and entertainment are
excellent marketing tools. Recognizing the difference, and making
sure everyone in your business knows it, is extremely important.
If there is any doubt, avoid the situation entirely.
'Facilitation
payment' is really nothing more than a synonym for bribe. It is
providing payment for a service to which you are already entitled,
usually in the hopes of speeding up this service. This could be
for something as simple as having a phone line installed to getting
paperwork pushed through more quickly. Of course, tipping a
waiter technically falls into this category as well, so you shouldn't
underestimate how easy it is to unwittingly cross this line.
Only
you can know all the potential trouble spots your business may
face. Identifying them all is the most important step.
However, once they are identified you must make equally certain that
you communicate everything to your partners and employees. They
must know what you are doing, why you are doing it, and, most
importantly, what controls are in place to make certain it is being
done.
If you'll permit me a sports reference, the follow-through is as important as the act itself.
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