Abstract

The question of what firms do internally in the fight against bribery is probably as important to the successful outcome of that fight as formal anti-bribery law and enforcement. This paper looks at corporate approaches to anti-bribery commitment and compliance management using an inventory of 246 codes of conduct. It suggests that, while bribery is often mentioned in the codes of conduct, there is considerable diversity in the language and concepts adopted in anti-bribery commitments. This diversity is a feature of the language used in describing parties to bribery and in defining which activities are prohibited (e.g. promising bribes versus actually giving them, gifts and entertainment, and solicitation. This diversity of language and concepts suggests that it might be useful to extend and deepen efforts in business associations and international organisations to build consensus on the meaning of bribery and corruption. In contrast, the bribery codes show evidence of an emerging consensus on managerial approaches to combating bribery. This involves the deployment of a distinctive mix of management tools, including financial record keeping, statements by executive officers, internal monitoring, whistle-blowing facilities, creation of compliance offices and threats of disciplinary action.