Anti-Corruption Certification

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Glossary of terms used on this site

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Term Definition
Indirect corruption

A bribe is paid by a third party working on the company’s behalf. The company is liable for the behavior of its third parties


Something that serves as an intermediary or agent through which one or more functions of a larger controlling entity are carried out: a part or branch especially of a governing body. In the US, the DOJ and SEC have construed “instrumentalities” to encompass State-Owned Enterprises (“SOE”). In the eyes of the DOJ and SEC, officers and employees of SOEs are all “foreign officials” under the FCPA


The quality of being honest and having strong moral principles

Internal controls

A process for assuring achievement of an organization's objectives in operational effectiveness and efficiency, reliable financial reporting, and compliance with laws, regulations and policies

ISO 19600:2014 standard on compliance management systems

Provides guidance for establishing, developing, implementing, evaluating, maintaining and improving an effective and responsive compliance management system within an organization

ISO 37001 standard on anti-bribery management systems

A management standard to help organizations in preventing corruption, by establishing a culture of integrity, transparency and compliance. It is a set of requirements

Italian Law Decree 231

States that legal entities, including limited companies, may be held liable – and therefore sanctioned by financial means or criminal proceedings – in relation to certain crimes which are committed or attempted in Italy or abroad in the interest or for the benefit of a company. Foreign and national companies are treated the same

Joint venture (JV)

A business entity created by two or more parties, generally characterized by shared ownership, shared returns and risks, and shared governance


The act of attempting to influence business and government leaders to create legislation or conduct an activity that will help an organization

Money laundering

The concealment of the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses

Negotiated settlement

A contract between two or more parties to resolve a legal dispute without a trial


The act of granting favors to relatives in various fields, including business, politics, entertainment, sports, religion and other activities

Non-prosecution agreement

A contractual arrangement between an enforcement authority such as the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the UK Serious Fraud Office, etc. and a company or an individual facing a criminal or civil investigation. Under an NPA, the enforcement agency refrains from filing charges to allow the company to demonstrate its good conduct

OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (1997)

Establishes legally binding standards to criminalize bribery of foreign public officials in international business transactions and provides for a host of related measures that make this effective.


Something that counterbalances, counteracts, or compensates for something else; compensating equivalent. For example, in the defense industry to offset the cost of defense procurement and to source the most cost-effective deals available, buyer countries often require defense vendors to make additional investments in the country, often worth 50 to 100% of the value of the main contract