By Jean-Pierre Méan
Published on Tuesday May 15, 2018
Anti-corruption training should obviously be shaped so as to support and promote the goal of an organization’s policy on corruption, which is (or should be), simply put, to encourage personnel to abstain from any corrupt behavior.
Most training programs attempt to reach that goal by providing knowledge of the organization’s anti-bribery policy and procedures and of the applicable anti-bribery laws, with an emphasis on the FCPA and on the UK Bribery Act because of their extraterritorial reach and also because they are in English and therefore easily accessible for organizations operating in a multinational environment.
However, in the discussions or arguments with commercial staff, which unavoidably arise, compliance officers are seldom faced with individuals who seek clearance for a violation of policy or a breach of the law. More often than not, the argument that they make is that there is no violation or breach at all, but e.g. that, in spite even of conclusive evidence to the contrary, the agent whom they want to use is perfectly honest and that there is no reason to doubt that he will respect his or her (written) commitment to live by the organization’s policy.
Where a violation of policy is (rarely) acknowledged, it is argued that it is justified by the circumstances with such arguments as “there is no other way to do business in that country” or “our competitors do it”. The purpose of these arguments is to “sanctify” in some way the violation by stripping it of its impropriety.
In a post on GAB, The Global Anticorruption Blog, Luana Vargas Macedo, the head of the anti-corruption unit of the Federal Prosecution Service in Palmas, the capital of the State of Tocantins in Brazil, provides valuable insight into the moral psychology of corruption. She points out that “when people act in accordance with their own moral standards, their brain-reward centers are activated”, which is gratifying for their self-image. Therefore, when individuals contemplate misbehaving, they use rationalizations to present to others, and more importantly to themselves, their behavior as morally acceptable, thereby maintaining their self-image intact.
Rather than focusing only on rules (which must admittedly be known), anti-corruption training should put the emphasis on the values underlying efforts to combat corruption and on the morally reprehensible character of bribery by highlighting its destructive impact on societies and by using real life scenarios, or dilemmas, from the daily routine of trainees. Discussing such scenarios in small groups is a good way to develop an awareness of the mechanism of rationalizations and to disarm them. It also serves to illustrate the spirit beyond the letter of an anti-bribery policy.
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nice article about anticorruption