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Dow Jones recently published the results of its fourth online survey on anti-corruption programs. Compliance officers of 383 companies worldwide (80 in North America, 145 in Western Europe, 119 in Asia-Pacific, 39 in other countries) participated in the survey and evaluated their anti-corruption compliance program. Currently 82 % of the companies have an anti-corruption program in place. Nearly all programs include internal codes of conduct and internal training. Most of them conduct due diligences on business partners (77 %). This number, however, is declining whereas the number of companies which do not monitor their business partners is slightly increasing. Many companies rely on the Transparency International Corruption Perception Index to evaluate their country risks. The number is decreasing, but the CPI remains the most-used information source (75 %). Over half of companies have delayed or called off business endeavors due to difficulties getting information to assess corruption risk (54 %), in particular in connection with Russia, China, Iran and India. 3 out of 10 companies spend USD 1 million or more on anti-corruption staff and policies per year. Spending levels are mostly consistent across regions and industries. Business partner due diligences are mostly handled by a central compliance team. About one third of the companies outsources this task. The business partner due diligences primarily focus on company ownership, financial performance and reputation. Fewer countries reported that they have lost business to competitors (33 %). According to the compliance professionals, the main reason why they had lost business was that their competitors were bound by anti-corruption regulations. Read the full survey here  


Nicolai Behr is a compliance and dispute resolution attorney in Baker & McKenzie’s Munich office. He is a member of the steering committee of GlobalComplianceNews, a compliance news website with global reach moderated by Baker & McKenzie. He is a member of the committee "International" of the German Institute for Compliance. Dr. Behr is a regular speaker on compliance and white collar topics.

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