The book gives readers a clear and thorough picture of the key elements
of who should form an anticorruption compliance program. Brian and Rick
hit all the key elements and in doing so provide sound, practical explanations
and guidance: from setting the overall tone for an organization through
anticorruption policies and procedures; to establishing proactive steps to
identify and monitor bribery and corruption risks throughout the organization;
to being prepared to respond when an issue is identified through an
investigative protocol/ombudsman process. At GE, we think of these elements
as ‘‘prevention, detection and response.’’ Each element is discussed in
a realistic and understandable manner. Brian and Rick also illustrate how
bribery and corruption issues may change over time and provide examples of
how a company’s anticorruption program should continuously evolve to
maintain its effectiveness—including ‘‘learning from misses,’’ since there is
no such thing as a perfect program.