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Integrity Pacts and Corporate Compliance Programmes: Contrary or Complementary?

Emerging Evidence from a Pilot Project in the EU

Claire Martin


Keywords: Civil society, Anti-corruption, ESIF

Recent years have seen the flourishing of laws and regulations requiring or encouraging the adoption of corporate compliance programmes, generally under national legal regimes and increasingly, as a condition for participating in public procurement markets. Companies invest considerable effort in putting compliance programmes in place and ensuring that they are effective. Such companies often express scepticism as to the added benefit other anti-corruption efforts, such as Integrity Pacts, can bring. This paper seeks to explore whether, as argued, the Integrity Pact approach duplicates corporate compliance programmes, or, is complementary of them. Drawing on experiences emerging from a pilot project underway in eleven countries in the European Union, the paper concludes that Integrity Pacts can bring a range of benefits that complement compliance programmes and can help address common gaps including supporting in managing risks, delivering training and demonstrating appropriate tone from the top. On this basis it recommends that firms should take a broader view of Integrity Pacts when assessing whether to integrate them into their compliance efforts. Keywords: Civil society; Anti-corruption; ESIF.

Claire Martin is Knowledge Coordinator on Transparency International’s Public Procurement work and project lead on the Safeguarding EU Funds through Integrity Pacts project. She received her LLB in Law and German from Trinity College Dublin and MSc in Development Studies from University College Dublin. In 2018 she also completed the short course on Procurement Anti-Corruption Training from the International Anti-Corruption Academy (IACA) in Vienna, Austria. This paper was produced within the context of that training. The author wishes to thank Professor Christopher R Yukins and Christine Mundia of George Washington University for valuable feedback on a previous version of this paper.


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