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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Resource Alert: New guidance for UK companies (and everyone else)

Transparency International UK rolled out a new tool Tuesday to help companies in the UK and overseas create anti-bribery compliance programs and evaluate their effectiveness.

The free online tool is called “Global Anti-Bribery Guidance: Best practice for companies in the UK and overseas.”

TI-UK calls it their flagship guidance.

It was created by “drawing upon expertise from over 120 leading compliance and legal practitioners and Transparency International’s extensive global experience,” TI-UK said.

FTI Consulting and DLA Piper helped create the new guidance.

No one can read it without learning or re-learning plenty of practical, useable stuff.

Here’s part of a quick “Case Study” under the Small Bribes topic:

In October 2016, the German authorities reached a settlement with logistics provider DB Schenker over allegations that it bribed Russian customs officials in the port of St Petersburg. Schenker agreed to a fine of €2m (U.S. $2.19 million) in settlement . . . As a result of the scandal, 30 Schenker executives lost their jobs in 2013. . . . The bribery scheme allegedly involved payments made to speed up the extremely slow customs clearing process in Russia for delivery of supplies to the nearby Ford plant.

Here’s part of the guidance about Charitable Donations:

Charitable donations, community investments and sponsorships can all be used as bribes. They can be made to support the pet cause of a public official with decision-making power over contracts or regulations that affect the company. They can be used to channel funds to front organizations controlled by a bribery recipient. They also present opportunities for employees to make inflated donations or sponsorship fees and receive money back from the recipients as kickbacks. . . . 

And this snippet about Gifts, Hospitality and Travel Expenses:

. . . high-risk area for bribery and have figured in a large number of FCPA cases. They present a challenge for companies to manage as most laws do not define boundaries while in many societies there are deep-rooted customs relating to gifts and hospitality. Best practice permits promotional expenses where they are transparent, proportionate, reasonable and bona fide. . . . 

The guidance covers 18 main topics, all of them relevant to any organization hoping to have a best-practices anti-corruption compliance program.

The editor of the Global Anti-Bribery Guidance is Peter van Veen.

It comes with a permissive (and generous) copyright notice that says, “Reproduction in whole or in parts is permitted providing that full credit is given to Transparency International UK and that any such reproduction, in whole or in parts, is not sold or incorporated in works that are sold.”  

“Global Anti-Bribery Guidance: Best practice for companies in the UK and overseas” is here.


Richard L. Cassin is the publisher and editor of the FCPA Blog. 

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