Can Private Sector Anti-Corruption Collective Action Find Renewed Importance?

Strong corporate governance, business ethics and robust compliance, underpinned by clear laws and effective enforcement, are critical to combat corruption. However, in its seminal 2008 Fighting Corruption through Collective Action: A Guide for Business, the World Bank Institute documented “a third area”: tools “that allow companies to come together collectively and voluntarily to raise practice standards and to reduce corruption,” including “integrity pacts… codes of conduct and collective public policy initiatives.” By uniting its efforts, the private sector can increase the effectiveness of companies’ internal practices and the regulatory framework. 

Since 2008, approaches have grown more sophisticated, thanks to players such as the UN Global Compact, the Basel Institute on Governance and its B20 Collective Action Hub, and the Anti-Corruption Collective Action Impact Centre at the International Anti-Corruption Academy. As the field matures, it is important to consider, as the Basel Institute asks in its March 2025 paper Anti-Corruption Collective Action: A Typology for a New Era, “how these commitments can be translated into practice” and avoid collective action “becoming a tick-box exercise”. 

In light of the new FCPA enforcement landscape and reduced foreign aid, I wanted to explore whether collective action can help fill the anti-corruption gap. To that end, I spoke with Brook Horowitz, CEO of IBLF Global, an NGO that engages with governments, multinationals and SMEs worldwide to raise standards and create a culture of private sector integrity. In 2013, as a knowledge partner of the B20 Anticorruption Task Force, IBLF Global co-authored with the Basel Institute the study “Design and Enforcement of Voluntary Anti Corruption Agreements in the Private Sector,” advocating for collective action approaches, and has since advanced collective action initiatives in emerging markets.  

Horowitz does believe that collective action is an effective way for the private sector to counter corruption, having seen the impact even in challenging markets. “While in highly corrupt environments, these efforts may not fundamentally change the overall landscape,” he says, “in certain circumstances, they can provide a minimum standard by which companies agree to operate and cooperate.” Even in Russia and China from 2010-2013, Horowitz says, companies could engage with one other and the public sector to advance responsible business practices.

He offers the example of his work in the healthcare sector in Russia in 2010, when IBLF Global convened the leading diagnostic equipment manufacturers  to develop a sectoral code of conduct. Additionally, in Vietnam from 2015-2019, IBLF Global supported the Vietnam Chamber of Commerce and the government’s anticorruption watchdog in a dialogue between SMEs and public officials, which eventually became a recognized government/business integrity initiative. But by the same token, Horowitz points out that collective action is not a panacea. The "strength in numbers” approach might ease concerns of companies about taking a public position, but officials may still target individual firms. Further, political dynamics can swiftly alter the landscape, as was demonstrated in Russia and China after 2013, and in Vietnam after 2019.

Now, despite pressures to the contrary, many companies are still seeking to promote ethical and sustainable ways of doing business. Even as the term “ESG” falls out of favor, he notes, companies recognize that without the “G,” their investments risk becoming ineffective or unsustainable, or even harmful to their interests. For that reason, Horowitz is focusing on working with companies that have committed to building a safer, healthier and more equitable world. Together with IBLF Global trustee Dr. Jan Dauman, he has brought together a team of researchers from IBLF Global and the UCL Centre for Sustainable Business on a project commissioned and led by Transparency International UK and British Investment International, to develop business integrity metrics and indicators for impact investors. As Horowitz puts it, “without sound governance, corporate green initiatives will be ‘gone with the wind’.” 

Marc Schleifer

Governance, Democracy and Economic Development Expert