Welcome to the TI-USA “toolkit” for Small and Medium-Sized Enterprises (SME’s) to develop anti-bribery compliance programs. As noted in Does a Company’s Size Make a Difference?, many SME’s need to have such compliance programs. In Overcoming Resistance/Inertia, you will find suggestions on how to get started. The “toolkit” provides guidance to assist SME’s in designing an anti-bribery compliance program that is harmonized with a company’s unique culture, risk profile, and existing mechanisms.

Policies, guidelines and training incorporated into a compliance program will vary from company to company depending on a number of factors, including, e.g., geographical and industry risks, corporate structure and culture. In the sections under Key Elements of an Anti-Corruption Compliance Program, there are sample risk assessment checklists and a collection of policies, procedures and training materials that could be adapted to fit almost any company.

The compilation of this “toolkit” is an outgrowth of the Survey of Best Practices for Corporate Anti-Corruption Programs published in 1996 by Transparency International’s US Chapter, which SME’s may also find useful. Because the resource materials are from US companies, the primary focus of the toolkit is compliance with the Foreign Corrupt Practices Act. However, the material can also be adapted for compliance with non-US anti-bribery initiatives; including those of the OECD, Council of Europe and the OAS.

The material and resources are provided as ideas for consideration by companies for the implementation and administration of their anti-bribery compliance programs; there is no intent to, and this toolkit does not, reflect or create a set of definitive standards or guidelines for such programs. This material is designed to provide information in regard to the subject matter covered. It is provided with the understanding that the provider is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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We wish to thank the following members of the TI-USA Small and Medium Sized Enterprise Task Force for their hard work and expert advice in developing the “toolkit”. Phyllis Erikson, J.M. Huber Corporation Leslie Hansen, J.M. Huber Corporation Carlo di Florio, PricewaterhouseCoopers DeWitt Rogers, Troutman Sanders LLP Katherine Atkinson, Miller & Chevalier LLP Walker Allen, Elementis, Inc. Doug Coleman, Curtiss-Wright Sheila Quarterman, Global Bridges ;

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