Transparency International (“TI”) is a well known NGO that focuses on advocating for integrity in public life in countries around the world. One of the areas that TI attempts to shed light on the problem through tools such as the TI Corruption Perceptions Index and by providing organizations that operate internationally with tools to help avoid situations where corruption might occur.

Usually these types of tools are directed at large companies; however, TI has produced a document called “Business Principles for Countering Bribery – Small Business Edition” to help SMEs deal with the same issues that large companies face. This is necessary because according to TI:

“More than 95% of the world’s business is carried out by SMEs which may not have the same human and financial resources as larger companies but are just as vulnerable to the risks of bribery.”

To SMEs, drafting a policy relating to anything can seem like an overly onerous task. Forget the process of actually investigating and enforcing the policy after it has been drafted. However, TI makes a good argument as to why an SME should consider implementing such a policy.

In addition to the fact that businesses and individuals have a responsibility to avoid engaging in these practices domestically or internationally under acts such as the Canadian Corruption of Foreign Public Officials Act, the US Foreign Corrupt Practices Act or the Criminal Code of Canada, there are also good business reasons to consider such a policy.

SMEs may have an indirect burden through their customer’s regulatory onus. Take for example the phrase from the aforementioned Business Principles for Countering Bribery:

“If you are hoping to do business with the supply chains of large companies, they will want to know if you have an anti-bribery Programme in place, because multinational companies are subject to particular laws and disclosure requirements which extend to their suppliers. Many large companies now have due diligence review processes, and if you have no anti-bribery Programme, your business is less likely to be selected, either
that, or you may have to sign up to their programmes.”

If your customers require you to have anti-corruption (and perhaps its close cousin “anti-money laundering”) policies in place as part of their supply arrangement with you, that may be motivation enough to draft these types of policies. The “Business Principles for Countering Bribery – Small Business Edition” is a good place to start.