How to Establish and Operate an Anti-Corruption Compliance Program in Emerging Markets : The Turkish Example

A compliance program, a tool which will enable companies to detect, deter and prevent any non-compliance with the applicable laws must be culturally adapted to the environment it will be implemented in. While there is some guidance on what the core elements of a compliance program should be, it should still be flexible enough to adapt to the changes that each jurisdiction brings with it in order to ensure a successful outcome. The importance of this flexibility can be clearly observed when a multinational company exports its business to different jurisdictions, e.g. emerging markets, where differing aspects of legal rules, enforcement and business culture come to light. Therefore, in order for a compliance program to work in different jurisdictions, adaptation of the compliance program to the sensitivities of the jurisdiction at hand becomes the foremost issue