- Tone at the top. Seen as the most critical to the success of a private sector anti-corruption initiative, this means the visible commitment by the CEO and senior management for the company’s anti-corruption policy—the so called “tone at the top.” This is more than merely making corporate announcements or strong denunciations about corruption; it is visible leadership.
- Anti-corruption training and accountability. All employees are trained and knowledgeable about the company’s anti-corruption policy. The training is done annually and employees certify in writing that they have received the training and understand the policy.
- Due diligence of foreign agents, consultants, and subsidiaries. Companies with international operations conduct enhanced due diligence of their agents, local partners, and consultants to ensure that they do not pose any risk of getting the company involved in corrupt acts.
- Internal control system. Companies put in place a system of strong, periodic internal auditing controls. For instance, many international accounting firms have adopted best auditing standards and practices, and apply them uniformly in all countries where they operate.
- Governments and public regulators:
- Civil society:
1. Combating Corruption-A Private Sector Approach (REFORM Toolkit). March 2008. Center for International Private Enterprise (CIPE).
2. "Corporate Responsibility of Multinational Organizations." In CMI Brief, Vol. 6, No. 2. Chr. Michelsen Institute (CMI), January 2007. Retrieved from http://www.cmi.no/pdf/?file=/publications/2007/2_07_web.pdf
3. MacMurray, W.D. September 2006. "Private Sector Response to the Emerging Anti-Corruption Movement." Retrieved from http://www.devoutreach.com/september06/SpecialReportPrivateSectorResponsetotheEme/tabid/1634/Default.aspx
4. "Making Anti-Corruption Regulation Effective for the Private Sector." 2009. In Policy Position No. 9. Transparency International (TI).