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Global Anti-Bribery and Corruption Survey 2011 (

Managing bribery and corruption risk continues to take center stage in corporate boardrooms. Many business leaders recognize the potential for significant reputational harm from public scandal; economic cost in the form of investigations, fines, and penalties; and individual cost in the form of criminal prosecution.

For many multinational companies, the enactment of the United Kingdom (UK) Bribery Act 2010, which criminalizes private sector bribery and the failure by a commercial organization to prevent bribery, only raises the ante. For others, continued high levels of enforcement activity by the United States (U.S.) Department of Justice (DOJ) and Securities and Exchange Commission (SEC), including imposition in 2010 of eight of the ten largest combined criminal and civil fines and penalties against corporations in the history of the Foreign Corrupt Practices Act (FCPA), has lead to a renewed emphasis on anti-bribery and corruption (AB&C) compliance activities.

Bribery and corruption exist in all parts of the world in varying degrees. Seven of ten executives we recently surveyed believe there are places in the world where business cannot be done without engaging in bribery and corrupt conduct. Of the remaining executives who do not believe bribery and corruption are endemic in some parts of the world, approximately 28 percent have nevertheless chosen not to do business in a country due to bribery and corruption issues.

Many multinational companies follow an approach which mitigates AB&C risk rather than eliminate it by opting not to do business at all. We surveyed 214 executives in the U.S. and UK to identify their most vexing AB&C compliance challenges and to understand how companies are preventing, detecting, and responding to AB&C risk.
The results of our survey indicate that, despite a greater awareness of the business and legal imperatives for welldeveloped AB&C compliance programs
among survey respondents, many compliance programs lack sufficient depth and breadth to effectively mitigate AB&C risk around the world.


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Vendredi 9 Septembre 2011

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