here - HUMBOLDT-VIADRINA School of Governance

2 major contexts to apply mitigation incentives
• There are two main contexts in which mitigation incentives can be applied:
Mitigation incentives
Context 1:
Before violation of anti-corruption
standard is known to stakeholder
e.g.: company self-discloses violation of anticorruption
standards (reporting) to
stakeholder
Context 2:
After violation of anti-corruption
standard is known to stakeholder
e.g.: company cooperates and enhances its
internal anti-corruption system
‣ Detects otherwise undiscovered corrupt
behavior
‣ Prevents from driving problems under
ground (i.e. break pact-of-silence)
‣ Offers ways back to legality, etc
‣ Motivate companies to enhance their
internal anti-corruption systems
‣ Motivate business proactive engagement
with stakeholder
‣ Recognize existence of ‘rogue
employees’ , etc
*Mitigation incentives are no ordinary incentives as they require a (threatened) sanction which can be reduced by the company through mitigating factors
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