The Organization for Economic Co-operation and Development has issued new guidance on internal controls, ethics, and compliance to help its member countries implement anti-bribery strategies.

The OECD Working Group on Bribery has issued “Good Practice Guidance on Internal Controls, Ethics, and Compliance,” which calls for companies in the 38 countries that are party to the OECD Anti-Bribery Convention to put in place strict internal controls and establish ethics and compliance programs as part of a strategy to combat bribery in international business deals.

The March 3 guidelines “put further meat on the bones” of the Working Group’s November recommendations, which contained, among a number of key guidelines, “an important international recognition by 38 signatory countries of the need for companies to adopt proactive compliance and ethics programs to combat bribery and corruption when operating abroad,” says Donna Boehme, a principal with Compliance Strategists.

Specifically, the Guidance calls on businesses to: “Adopt a clear and visible anti-bribery policy that is strongly supported by senior management; instill a sense of responsibility for compliance with the policy at all levels of the company, as well as independent compliance structures; keep up regular communication and training on foreign bribery for all employees, as well as with business partners; and encourage observance of anti-bribery compliance measures, and disciplinary procedures to address their violations.”

The Guidance, which forms Annex II to the Working Group’s Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions, also recommends that business organizations play a leading role in providing information, advice, and training to companies, especially small- and medium-sized enterprises, on how to protect themselves against the risk of foreign bribery.

Boehme says the Guidelines not only incorporate the key principles of the Federal Sentencing Guidelines—including strong senior management tone and action, clear standards, protocols and internal controls, communication and training, and effective, appropriate disciplinary procedures—but in some respects, she says the guidelines “reach even further to validate the concepts of independent oversight and empowerment for the chief compliance officer.”

While the guidelines don’t have formal legal impact, the OECD Working Group will monitor each member country’s progress in encouraging companies to implement the guidance.

“We already have seen how this can be an effective change agent in how member countries approach anti-bribery and anti-corruption measures—expect to see more of the same as the Good Practice Guidelines are rolled out,” says Boehme. “It may take time, but this is an enormous step in ‘internationalizing’ the proactive approach of the FSG. Chief compliance and ethics officers should be proactive in educating their senior management and boards about this development and its impact on how countries beyond the United States are looking at bribery and corruption.”