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

Turkish Commercial Law Review, Vol. 1, No. 2, June 2015

8 Pages Posted: 10 Dec 2018

See all articles by Gonenc Gurkaynak

Gonenc Gurkaynak

ELIG Gürkaynak Attorneys-at-Law

Olgu Kama

Norton Rose Fulbright LLP

Burcu Ergün

ELIG, Attorneys-at-Law

Date Written: June 2015

Abstract

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.

Keywords: FCPA, UKBA, compliance programs, Turkey, corruption

JEL Classification: D73

Suggested Citation

Gurkaynak, Gonenc and Kama, Olgu and Ergün, Burcu, How to Establish and Operate an Anti-Corruption Compliance Program in Emerging Markets: The Turkish Example (June 2015). Turkish Commercial Law Review, Vol. 1, No. 2, June 2015, Available at SSRN: https://ssrn.com/abstract=3285843

Gonenc Gurkaynak (Contact Author)

ELIG Gürkaynak Attorneys-at-Law ( email )

Çitlenbik Sokak No:12
Yıldız Mahallesi
Istanbul, Beşiktaş 34349
Turkey

Olgu Kama

Norton Rose Fulbright LLP ( email )

United States

Burcu Ergün

ELIG, Attorneys-at-Law ( email )

Çitlenbik Sokak No:12
Yıldız Mahallesi
Istanbul, Beşiktaş 34349
Turkey

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