Friday, April 27, 2012


Who's corrupt?


According to Infoplease, The United States failed to make the list of the Top Twenty Least Corrupt countries for 2011.

The determination was made by Germany's Transparency International. The Germans define corruption as the abuse of public office for private gain and measures the degree to which corruption is perceived to exist among a country's public officials and politicians. It is a composite index, drawing on 13 different expert and business surveys.

On the other hand, the US also failed to make the Bottom Twenty Most corrupt list. Certainly nothing to write home about.

The lists, if they are at all accurate, tells Enterprise Risk Management practitioners that corruption is a serious threat to the organization.

Since most practitioners lack the expertise to ferret out corruption in an organization, the questions become:

  • To whom does the practitioner turn?
  • Who IS the anti-corruption Subject Matter Expert (SME)?
  • What can be done to prevent or at least discourage corruption?

Several things come to mind, the most important of which is GET TOP MANAGEMENT TO SET AN EXAMPLE and to make clear management's expectation of all personnel.

Sans flag-waving support form the Board Room and Executive Suite, the practitioner's best efforts will be for naught. Very Senior Management must be an enthusiastic example to the troops.

This admonishment is, of course, the standard chorus for all risk management/business continuity activities.

I am embarrassed that the U.S. isn't at the top of the Least Corrupt list, but I predict -looking into my very foggy crystal ball - that the country will do better. The reason for my optimism is the government's increasing enforcement of the Foreign Corrupt Practices Act (FCPA).

Perhaps the threat of Big Brother - or perhaps "Big Uncle (Sam)" - watching will encourage Very Senior Management to do what is necessary for top-down awareness and compliance with national laws in the U.S. and the countries where the organization does business.

If I wrote it, you may quote it.

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