May 21, 2026

Suitcases full of cash, shady figures, or backroom deals are the clichés associated with corruption. This image has little to do with the day-to-day business of many companies.
Risks often arise in everyday situations, especially when decisions need to be made under pressure: a stamp is missing at customs. A tender is canceled. Or a third party “helps” with contacts that no one can properly explain.
In the absence of clear instructions on how to act in such situations, the risk of making wrong decisions increases. This can lead to the search for creative solutions that lie outside the legal framework. Companies should therefore systematically limit corruption risks through prevention, detection, and response.
Prevention helps to prevent problems from arising in the first place and is the first step in combating corruption. This involves a company establishing clear rules for situations where there is pressure. This includes written guidelines, defined responsibilities and transparent processes in critical areas. Measures should be proportionate to the risk. Not every situation requires the same level of effort. The key is that investigations and decisions are traceable and documented. This reduces the burden on day-to-day business and strengthens the evidence in the event of a serious incident.
A sensitive area of practice is gifts, invitations, and similar favors. They may be part of relationship building. However, they also carry risks. Favors must never influence a business decision or give the impression that they do. Favors to government officials are particularly sensitive. Caution is required here.
A simple three-stage system can provide guidance in this area:
Grants below the internal amount limits, decision usually made within one’s own competence (i.e. without explicit approval by other responsible persons), e.g.:
Small, non-personalized promotional gifts and symbolic tokens of courtesy
Invitations for coffee, simple/appropriate business lunch
Events of a purely business nature such as product presentations
Grants for which explicit and documented approval is required, e.g.:
Grants without an apparent business connection
Events with an entertainment character and/or private accompaniment
Invitations for officials
Travel or accommodation costs, speaker fees/honoraria
Charitable or political donations, sponsorship commitments
Gifts that are not allowed. Such offers should be rejected and documented internally, e.g.:
Gifts expressly prohibited (law, internal rules)
Grants with the purpose of influencing decisions or direct link to a consideration
Gifts and invitations to officials or persons closely associated with them / organizations
Intransparent donations (e.g. sending to a private address)
Cash and cash-like gifts, luxury gifts or invitations
Source: Transparency International, Guide to Gifts and Invitations
It is also important to deal with third parties in order to prevent an ethical company from being unwittingly involved in corrupt practices through its business partners. Therefore, there needs to be a clear approach to working with agents, distributors, and brokers. This includes a risk analysis of the business relationship, a risk-based integrity check, and a contractual commitment to corruption-free conduct.
Corrupt behavior is more likely to occur when three factors come together: opportunity, motivation, and justification.

Source: Transparency International, Guide to Gifts and Invitations
Even good rules do not replace the review of suspicious incidents. Many problematic processes are not immediately apparent. That is why controls are needed in the right places. These include partner selection, compensation, commissions, payment processes, gifts, and invitations. Where appropriate, documentation in a register is helpful. Spot checks and plausibility checks reduce the risk of circumvention.
With third parties, a simple but consistent check of warning signals is worthwhile. An effective tool for this are red flags, i.e. circumstances that indicate an increased risk. They are a signal to look more closely.
Red flags with third parties and payments (selection)
Source: Transparency International, Business Partner Risk Guide
Such indications do not automatically mean that a partner is corrupt. However, further investigations are necessary to actively reduce risks.
When a situation turns sour, the response is crucial to prevent further risks. This includes not making commitments, not triggering payments, and reporting the matter internally. Then, there needs to be an assessment and a decision on how to proceed.
An important component is the ability to report irregularities. Whistleblowing is the reporting of wrongdoing within a company. For reports to be effective, they must be investigated promptly. Any irregularities found must be rectified, and appropriate consequences must be imposed for violations.
In addition to local law, Swiss law is also relevant for Swiss companies. Furthermore, foreign law may also apply, especially extraterritorial law such as the US Foreign Corrupt Practices Act or the UK Bribery Act.
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