Is robust ABC possible?

After the last newsletter Romain Caillaud responded to the question about other topics saying:

“How do you propose to approach the creation of a robust ABC policy that can realistically be understood, bought into and implemented across multiple borders and cultures?”

So let’s try!

Check your privilege

A familiar refrain, but it could equally be termed ignorance is bliss. It can be challenging to understand for those of us lucky enough to grow up (or live in) countries where corruption isn’t a feature of daily life. Ask:

1. How frequently are you asked to pay a bribe? (e.g., seeing a doctor, driving unimpeded, getting your kid’s school paper graded).
2. What happens if you report the request for a bribe?
3. What are the euphemisms used for bribes?
4. What are acceptable forms of gifts, entertainment, hospitality and donations?
5. What have you seen work when resisting an unethical request?

These questions require trust to answer and an understanding of power differentials. Using surveys, anonymous polling tools, or leading with examples and scenarios (and asking people to rate the plausibility) can help overcome the silence. We’re intentionally asking questions outside of work for obvious reasons, not least a better contextual understanding.

The goal is not to give up and resign to this scourge continuing, but to recognise that we’re not all starting at the same spot, which we reflect in resources and support.

Critical path

Critical path may sound the name of a 90s experimental rock band, but it’s about planning for problems. If you’ve established that certain countries (or sub-regions within a country) present elevated risk, now what? Ask your colleagues:

1. What clients, services or inputs can we not operate without?
2. Are there alternative (less corrupt) options to secure those clients, services or inputs?
3. Can we avoid these groups altogether? For example, routing all shipments through a less problematic port?
4. If not, can we plan for delays? Or enlist allies (e.g., diplomatic support, industry associations, other firms in a similar situation, etc.) to influence?

I’m not suggesting it’s easy or immediate, but it is possible, somehow. You cannot operationalise anti-corruption if it’s not implemented operationally.

Mirroring

Now, when you create your anti-bribery & anti-corruption (ABAC) policies, training, and communications, you will hopefully have a better idea of what is:

1. Widely understood
2. Overlapping
3. Relevant

Don’t lead with what NOT to do if people get it. Often policies start with the legalese “what happens if we’re naughty” bit. That may make sense, but it’s a bit like lecturing a long-haul trucker on adequate rest when you’ve set them a delivery schedule that doesn’t allow for rest – it may breed resentment, cynicism, and them ‘n’ us. Perhaps start with something honest – recognising the challenges and setting out how we will work together to solve them.

If there isn’t that baseline understanding (common in gifts and entertainment), then sure, lead with some “why it matters”.

I remember a colleague who’d lived in Russia meeting a counterpart from Brazil for years. After five minutes of chatting, they declared, “We worked out that aside from the weather, we have pretty much the same problems.” Overlapping experiences of managing corruption risks can be powerful learning tools and build a sense of global camaraderie. If your Nigeria team has overcome customs’ pesky demands, might that help other colleagues in maritime markets?

The information and stories you gather ensure relevance. There are few more valuable currencies in E&C work. Use every nugget you glean to the fullest.

Concluding corruption conundrums

This is a brief newsletter, and therefore, very abridged. You may have noticed I didn’t mention the law; why? Because corruption is universally illegal (pedants may pick on facilitation payment exceptions). Most folks get the concept. What makes them lose faith is a lack of empathy, relevant support (”say no” doesn’t work in many scenarios), and realistic targets (20% growth in a kleptocracy is seldom possible, cleanly).

Meet people where they are, use examples that resonate, explain it’s a we problem, not a you one, and celebrate those who win, resist, or overcome ethically.