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Level 1 - Foundation

Provided by the International Finance Corporation

This level helps lay the foundation for firms to conduct its business with integrity, starting with a modest internal program, and protecting itself from solicitation for bribes and extortion.
Level 1 includes basic internal activities that a firm can begin to organize and implement in order to create a good foundation for integrity in business conduct.
Internal Integrity Program
As part of the Internal Integrity Program, you should:
  • Analyze recent interactions with business partners and public officials and assess risks
  • Take time to consider a longer-term firm strategy
    • Include integrity performance as part of business objectives; set goals
  • Introduce an integrity policy, principles, rules or a statement that everyone will follow
    • Make it official that bribes won’t be paid
    • Openly discuss with employees about the importance of integrity
    • Make clear what payments are allowed / not allowed; for example, facilitation payments –
      • If payment is demanded, actively resist
      • If payment was made, inform manager
      • Keep the amount to a minimum
      • Create a record for a payment
  • Create and maintain internal systems and controls
    • Keep accurate books and records
    • Have clear rules on contracts, payments to business partners
  • Understand how to improve corporate governance of small businesses 
    • Clearly define responsibilities among owners and employees
Protection from Solicitation and Extortion
To protect your company from solicitation and extortion, follow these rules:
  • Put requests to public officials in writing
  • Before a meeting with a public official:
    • Find out about the official’s background
    • Have all necessary documents ready
    • Seek legal analysis beforehand if complicated issues are involved
    • Rehearse arguments such as an actual case that supports an SME
  • Dos/don’ts during a personal interaction with public officials
    • Have a witness or record interactions ( check that such recordings are legal in your country)
    • Ask questions and create a paper trail; e.g., ask for a written receipt of payment 
    • Instead of a bribe, offer an alternative with a public or civic benefit
  • Following up after a personal interaction with public officials
    • If an agreement was reached during a meeting, follow up with a letter
    • If any promise was made, track the official’s performance
    • Draw up a plan for future discussions


Go Forward to Level 2 > Demonstration

Go to the SME Integrity Tool Parent Page

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