• Is there a bribes policy and are employees aware of it?
• Have bribes been demanded or paid?
• How much and how often?
• Have they been successfully avoided?
• What do your employees/partners do when they suspect corruption?
• Are projects designed to prevent bribery?

1. Conduct a risk assessment: where is your organisation exposed to a high risk of bribery – and how effective are your anti-corruption policy and management systems?
2. Introduce a zero-tolerance policy: put in place a headline policy that recognises the damage that corruption does to your goals and mission; the importance of strong internal anti-bribery systems; and makes it clear that the organisation does not tolerate bribery in any form. Establishing a reputation for not paying bribes is an important start.
3. Put in place strong anti-bribery systems: Key areas to consider include procurement systems, audit and ‘whistle-blowing’. Transparency International (TI) produces a checklist to assess anti-corruption procedures (see reference below) - although aimed at companies, it is also relevant to NGOs.
4. ‘Design out’ bribery from future projects or operations: embed anti-corruption measures in project design. For instance, set achievable timescales, train staff and take care in selection of partners and suppliers.
5. Gather local knowledge and information: it is important to know whether bribes are being paid by your employees, agents or partners – and if so where, how much, and how frequently. Find out which government departments or officials are less corrupt, which ports are corruption-free.

6. Provide training and support: implementing effective anti-bribery systems can be a difficult process, and employees and partners may feel vulnerable and ill-equipped, especially in a transition phase from one way of doing things to another. Proper training and support is a vital part of this process.

7. To pay or not to pay? Never refuse when your personal security is threatened. Depending on the situation, you could refuse to pay or ‘play ignorant’ and find yourself being waived through or receiving the service anyway.
8. Seek creative solutions – are there alternative options, eg can you buy equipment in-country rather than having to import and pay “special” customs fees?
9. Consider collective action – if enough organisations and companies resist paying bribes and share information, some endemic corrupt practices will be forced out. Publicising known regular corrupt practices in the local media – such as the infamous road block on airport roads – could also have a positive impact.
10. Seek advice - contact the local TI chapter or embassies for advice on local resistance strategies, and to report corrupt practices.

Remember: You do have a choice! Many organisations refuse to pay bribes. It may make some operations more difficult to run… BUT saying no to bribes helps create a better society.

• Transparency International has experts able to assist NGOs in developing anti-bribery systems and publishes a selection of tools for risk. See www.transparency.org
• Mango is working with Transparency International to develop an anti-corruption training course. Further information from training@mango.org.uk
• Join Mango’s Getting the Basics Right (FM1) course to learn about robust financial management systems; and see Mango’s Guide to Financial Management for NGOs, www.mango.org.uk/guide, for free advice and tools, including sections on internal control, procurement and audit.

Mango: Inspiring NGOs to make more of their money We run training courses, recruit finance professionals, provide consultancy and internal audit services and publish free tools & guides www.mango.org.uk

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Top Tips Archive

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5. Reading Budgeting Monitoring Reports
6. Cashflow Forecasts
7. Tips for Finance Trainers
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10. Controlling Costs
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15. Recruiting the Best Finance Staff
16. Stages of Procurement
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