In fact the things are different - companies involved with any kind of international business need to implement certain protection measures against corruption and be able to prove that they observed the specific requirements in the field. How can you ensure that your business is protected from the consequences of other people’s corruption?
Neil McGregor, Managing Partner at McGregor & Partners, offers a series of useful advice, in this regard, to companies in Romania:
1. Don’t ignore the issue. Read and revise, as the case may be, your organisation’s policy and guidance on anti-corruption and business ethics. Do they cover everything which is relevant to your business? If your organisation does not have a formal policy and set of guidelines on anti-corruption and business ethics, this situation must be corrected as soon as possible. Make arrangements to draft and publish an accessible formal policy and set of guidelines and communicate them to your staff and business partners.
2. Check if there are any new employees (and, especially, managers and administrators), new business partners, as well as any changes in the management or ownership of any of your business partners, in the last year. Make sure (and get proof) that they are aware of do understand your policy and guidance on anti-corruption and business ethics.
3. If the contracts which your organisation uses include anti-corruption clauses, consider reviewing whether there are any signs or suspicions that there have been breaches of these clauses. If the there are no signs of problems, make a formal record of this.
4. Make regular checks of your register of hospitality and gifts, given and received. Is it up-to-date and complete? Is there anything in there which you may have trouble to explain? If so, find out more about the gift or hospitality concerned and record what you have done.
5. Make sure you have a formal risk assessment report on the risks of bribery in the countries and markets where you operate. Make periodical checks that it is still correct or whether it need to be updated (e.g. if you have started doing business in a new market or have new business activities?), if your employees have reported concerns and how can you prove that they understand that you wish to be notified, should such concerns arise.