Training, financial controls, and monitoring are the bread and butter of compliance programs. But to truly understand how to prevent bribery within our organizations, compliance leaders should look beyond the basics and consider motives. Bribes are ultimately paid by individuals, and it is reasonable to ask how those individuals decide to engage in bribery, even in the face of compelling disincentives: criminal penalties, social opprobrium, dangers of complicity, and legal and religious condemnation.
Setting aside individual bribes paid in exchange for necessary goods and services—like medical care or a driver’s license—how can we better understand the psychology and motives behind business bribery? And how can it help us in our compliance efforts?
First, we need to recognize there isn’t just one “psychology.” Corruption—and its condemnation—have been around forever, but psychology as a scientific discipline goes back only to the mid-19th century. Some of these models may be older than others, but none has ever fully disappeared. So rather than digging into the latest developments, let’s consider how a range of psychological concepts bears on practical compliance issues.
Moralism assumes that humans have free will and can decide between conduct that is right or wrong—philosophically, naturally, or by divine command. For our purposes, bribery is understood to be wrong, and the individual’s decision to engage or not is understood within a frame of temptation, fall, and redemption. (Some sort of moral arc can be found in all religions). In practical terms, compliance leaders can incorporate this concept by telling stories about individuals or groups facing an ethical challenge and making the right or wrong decision, followed by an instructive examination of how that plays out, both individually and at the community or organizational level.
Under this model, which is fundamental to economics and economics-based legal theories, we are all rational agents evaluating which actions will produce the best outcomes for ourselves. Rationalism sets aside notions of right versus wrong and assumes a predictability to human behavior. A thought exercise through the lens of rationalism can reveal compliance risks within existing company structures: the role of incentives, for example, including how commission-based compensation structures or rigidly aggressive sales goals might lead to bribery.
Behaviorism examines human action as a result of stimuli through interaction with the environment. As a compliance leader, you should enact behavioral interventions that will affect norms and actions within your organization to reduce risk. This could include interventions into how people think about corruption—for example, by communicating its tangible consequences—and using training to rehearse likely scenarios so the correct response becomes natural and almost automatic.
There are many ways to classify people into different “personality types,” from the so-called humoral types of antiquity (phlegmatic, choleric, sanguine and melancholic) to psychoanalytic categories of pathology (narcissistic, obsessive, paranoid, etc.) to classifications like the familiar Myers-Briggs type indicators (INTP, ESFJ and all combinations in between). Some of these can be useful for understanding particular personal dynamics that lead to compliance challenges. Of course, personality types shouldn’t be used to predict someone’s likelihood of engaging in bribery: None of us should be considered immune in that respect. But as we proceed with crafting our moral narratives, our rational incentives, and our behavioral interventions, we should remember that different people will respond in different ways.
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Here as elsewhere in compliance, there is no one-size-fits-all solution. The most effective programs speak to people at all stages of their enthusiasm for rule-following, from the keen intern in the front row at every live training to the cynical business development manager at the back scrolling through his email and looking up only when he hears references to termination or jail time.
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