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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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

The surprisingly diverse world of anti-corruption policies

We have benchmarked fifteen anti-bribery policies from some of the world’s largest and best-known companies that cover an estimated 4.2 million employees. With an unexpected amount of variety among the policies, here are some interesting things we’ve learned.

Not about word count. 

The wordiest policy we’ve seen so far is Volkswagen at 36 pages. Unilever is the shortest at a single page.

The average length is 9.5 pages.

Facilitation payments: Yes, no . . . maybe?

Eleven companies prohibit all facilitation payments: Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer.

Three companies say they will allow facilitation payments in certain circumstances: Coca-Cola, Tesla, and ExxonMobil.

Seven of the fifteen policies specifically mention an exemption for duress or extortion. Eight others don’t mention the unpleasant topic.

Walmart is the only company that doesn’t mention facilitation payments at all (it doesn’t mention extortion or duress either).

ExxonMobil is the only company that allows some facilitation payments and has an extortion defense.

Not so tony at the top. 

Disney and ExxonMobil are the only policies that have an introduction by the company CEO.

View the anti-corruption policy benchmarks here.

We’ve got more anti-corruption benchmarks coming up.

P.S. If you work for any of the companies that we’ve already benchmarked and your company has updated or changed your policy, please let us know.

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