Answer ... Top tips for a robust anti-corruption compliance programme include the following:

• Understand your business risks.
• Design a compliance programme to match the risks.
• Implement the programme from top to bottom with support from top, middle and every level of management, so it is seen to be believed by everyone from the CEO and CFO to the newly appointed administration clerk.
• Ensure the programme applies to all third parties in your supply chain.
• Train and educate everyone on a regular basis on the programme, monitor it, review it and update it as business risks change.
• Promote a culture of disclosing misconduct and protecting the discloser.

Potential sticking points for a robust anti-corruption compliance programme include the following:

• lack of robust internal leadership;
• lack of adequate resources for compliance training, education, monitoring and review of the programme;
• too great a focus on short-term financial goals over longer-term sustainable goals;
• a willingness to ‘get the job done’ or to ‘do it the local way’ to secure a contract or business advantage, turning a blind eye to the programme and ethical values of integrity; and
• a prevailing culture of ‘Don’t dob in a mate’, which helps to shroud misconduct.