Bribery is becoming a high priority public concern and the legal framework and enforcement apparatus used in the fight against it are being developed in the OECD and elsewhere. Reflecting these civic and legal pressures, firms now often deal with bribery in their codes of corporate conduct – public statements of commitment to abide by a certain standard of business conduct. The question of what firms do internally in the fight against bribery is probably as important to the successful outcome of that fight as formal anti-bribery law and as the attitudes of the public. This paper looks at corporate approaches to anti-bribery commitment and at managerial approaches to implementing these commitments in an inventory of 246 codes of conduct.

The paper shows that, while bribery is often mentioned in the codes of conduct, there is considerable diversity in the language and concepts adopted in anti-bribery commitments. This diversity is a feature of the language used in describing parties ...