Other Guidance on Compliance and 2010, were drafted based on consultations with the private ; } sector and civil society and set forth specific good practices International Best Practices y eee gor 2 In addition to this guide, the US. Departments of for ensuring effective compliance programs and measures Commerce and State have both issued publications that contain for preventing and detecting foreign bribery. In addition, guidance regarding compliance programs. The Department businesses may wish to refer to the following resources: of Commerce’s International Trade Administration has pub- ¢ Asia-Pacific Economic Cooperation—Anui- ; sponge: 335 lished Business Ethics: A Manual for Managing a Responsible Corruption Code of Conduct for Business Business Enterprise in Emerging Market Economies, and the ¢ International Chamber of Commerce—ICC Rules ; +99 0336 Department of State has published Fighting Global Corruption: on Combating Corruption; Busines Rie Managemen ™ e Transparency International—Business Principles for : “Dy oyraye337 There is also an emerging international consensus on Countering Bribery; compliance best practices, and a number of inter-govern- * United Nations Global Compact—The Ten sa rip |e 338 mental and non-governmental organizations have issued Principles; guidance regarding best practices for compliance.*” Most ¢ World Bank—Integrity Compliance doin p¢-339 notably, the OECD’s 2009 Anti-Bribery Recommendation Guidelines and and its Annex IL, Good Practice Guidance on Internal * World Economic Forum—Parmering Against ; nj ; ; 4 Controls, Ethics, and Compliance?* published in February Corruption—Principles for Countering Bribery.” OO ————eeeeeeeeeee—C—C“‘#CO#NN Hypothetical: Third-Party Vetting Part 1: Consultants Company A, a U.S. issuer headquartered in Delaware, wants to start doing business in a country that poses high risks of corruption. Company A learns about a potential $50 million contract with the country’s Ministry of Immigration. This