The US Foreign Corrupt Practices Act (FCPA), one of the most
well-known and relatively stringent anti-corruption legislations in
the world, appears to be the flavor of the season with another
large organization being recently subject to an investigation with
regard to potential improper payments by its Indian subsidiary. The
corporation in question is a leading multinational with widely
acknowledged best practices and a strong governance focus. So what
could have possibly gone wrong?
Most multinational companies, who can be subject to
investigations under the global anti-corruption legislations, have
an anti-bribery and corruption policy and a whistleblowing
mechanism to support. The policy helps demonstrate the 'tone at
the top.' Is having a written anti-corruption policy and
whistleblowing mechanism enough?
