The two-thousand-euro favour, and the trap that opens behind it

In short: Fifty thousand euros of milk is rotting in a port and a local agent wants two thousand in cash to release it. That dilemma opened Roland Notermans’ webinar on gifts, hospitality and the point where a courtesy quietly becomes a bribe. His case: the amount on the receipt tells you almost nothing, naivety does more damage than malice, and a real programme has to reward the right behaviour, not just forbid the wrong one. The fuller account is below.

Fifty thousand euros of milk is sitting in a port in a hot country, and in six hours it will be worthless. Customs will not release it, insisting the paperwork is wrong, though you are fairly sure it is fine. Your local agent says he can make the problem disappear with two thousand euros in cash, and that it would be better not to ask too many questions. Your country manager is on the phone. What do you do?

That was how Roland Notermans of De Compliance Academie opened his Week of Integrity webinar, a session on the most everyday corner of anti-corruption and the hardest to police: gifts, invitations, hospitality, and the point where a normal courtesy quietly becomes a bribe. He put the milk dilemma to a live vote. Almost nobody said a flat yes. Almost nobody said a flat no either. Most people picked the third option, which was some version of “wait, let me ask a few things first.” That, he said, is exactly the right instinct, and then he drew the questions out of the room. Why two thousand, and why can we not ask what it is for? Can we get a written description of the work so the money goes to a named third party for a defined task, and not into the country manager’s own pocket, which, he noted dryly, does sometimes happen? Is there another customs agent? Has the embassy seen this before? Should we even be using this port?

Then he sprung the real lesson. What if it were not two thousand euros, but two hundred? The room split the same way, and that was the point. It almost always starts with a small amount, he said. Once they know you are willing to pay, you go onto a list of companies that will pay, and next time it is four hundred, then eight hundred, and with a little bad luck someone films you on a phone and now you are blackmailable. In Dutch he called it walking into a fuik, the funnel-shaped fish trap you can swim into but not back out of. It is a better image than any policy clause.

A second dilemma set up the other half of his message. You are bidding for a government contract abroad, and the official hints that your chances would improve enormously if you took on a particular firm as subcontractor. The firm actually looks useful. Do you hire them? Several people said no outright, and this is where Notermans pushed back in a way worth repeating. If your first word is always no, your department becomes known as the no department, the place where compliance will not allow anything. He said he is far more interested in which questions you ask and what homework you do to see whether you can make the business happen. The red flag here is not the subcontractor; it is the official steering you toward them. So you check what sits between the two of them, family ties, kickbacks, reputation, and you get a competing quote. In the Netherlands, one participant from an airport pointed out, a contracting authority prescribing your subcontractor would itself be improper; the specification should be objective and the choice yours. The conclusion was not “walk away,” but “do the homework, keep asking, and be able to prove you looked before you leapt.” In the darkest-red countries on the corruption map, think about it two or three times. But do not confuse caution with simply saying no.

Why this is not a victimless technicality

Notermans spent a while on why any of this matters, because he thinks most organisations are quietly naive about it. The five largest bribery fines on record each exceed a billion euros, he said, and the fine is the smallest part of the cost once you add the management time, the external investigators and lawyers, and the reputational damage. People have gone to prison. The money that corruption diverts does not reach hospitals, medicines, infrastructure or clean water; it pools with a thin elite and with the politically exposed people around them.

He leaned on a framing he credits to Professor Muel Kaptein of KPMG, who ran his own Week of Integrity sessions the same morning. Roughly one percent of people, Notermans said, are actively corrupt, and about one percent are completely honest no matter what. The other ninety-eight percent let the circumstances of the case decide. That is the whole job, more or less: most people are movable, so the environment you put them in does the deciding. In his experience the problem is far more often naivety and ignorance than malice, people convinced that “we have always done it this way, for the good of the company,” or that “if we do not, the competitors will.” The good news in that, he said, is that ignorance is the easiest thing to fix, through training, dilemmas and conversation. Kaptein, he noted, once catalogued more than sixty excuses people give for crossing the line.

So where is the line on a gift?

This is the question in the title, and his answer is bracing in its simplicity: the amount tells you almost nothing. A threshold in a policy (“register anything above a hundred euros”) is a useful trigger, not a moral test. His example: a bottle of champagne worth forty-nine euros may be fine once, but if it arrives again the second week, and certainly by the third, the right question is not “is it under the limit” but “what is going on here, and why is this actually highly inappropriate?” The test he kept returning to was simply, is this appropriate in these circumstances? Frequency, who it comes from, what decision is in the air, and whether it is registered and visible all matter more than the number on the receipt. And the practical aim of the whole gifts policy, he said, is not to be watertight in a courtroom but to make sure the average colleague knows when and where to raise a flag when faced with gifts, entertainment, amusement or an improper advantage.

He also made a small but sharp point about language. Nobody wants to attend an anti-corruption course, because everyone is sure they neither bribe nor take bribes. But gifts and hospitality happen constantly, and that is precisely where the risk lives, so that is what you talk about.

Building something that actually works

Most of the hour was Notermans’ framework for a real anti-corruption programme, which he numbers as seven elements, the six from standards like ISO 37001 plus one he adds himself. A few threads stood out.

Start by accepting you cannot be a hundred percent clean, he said, but do not use that as permission to do nothing. Only an organisation that works properly at an effective programme has an argument to keep a fine low when one case slips through; a paper exercise earns a bigger fine and a worse headline. The programme has to be proportionate to you: a Dutch-only bakery does not need what Heineken, operating in dozens of countries, built. Risk tracks the business model too. Buying and reselling boxes is lower risk; project and construction work is far more dangerous, because there is no clean market price, so invoices can be inflated and money skimmed. And it must rest on a risk analysis that is repeated and documented, done by a small group of experts, never filled in by a sales manager alone, because the conflict of interest is built in.

His most insistent theme was that “tone at the top” is overrated. After advising more than a hundred Dutch companies, he said he worries much less about the executive board than about the four or five layers beneath it, ambitious managers chasing promotion who are not always willing to stick to the rules. An anti-corruption programme that does not put responsibility on the line manager, he warned, is doomed to stay a nice head-office exercise that never reaches the countries you actually need to reach. And the incentives have to line up, or nothing else matters. He cited Wells Fargo firing more than five thousand employees who had crossed the line to hit their bonuses, and asked the obvious question: if you tell a salesperson integrity is vital but set a hundred percent of the bonus on revenue, and for three years the only feedback is “well done,” what have you actually told them? He has a word for getting this right, “congruence,” which he admits is clunky: the programme has to reinforce itself, with appraisal, bonus, communication, the code and sanctions all pointing the same way, or the board’s talk about integrity pulls the credibility out from under the whole thing.

The circle has to extend past your own staff to third parties, the agents and consultants who so often carry the actual bribe. He pointed to Walmart in Mexico using law firms to grease permits, and to a client who, after an incident at a competitor, cut forty-five sales agents down to three. Contracts should say how partners must behave and give you the right to terminate on a credible accusation, and the due diligence should be deeper where the risk is higher. He added a warning most people forget: think about where your screening data physically sits and which governments can reach it, noting that the large majority of the biggest US enforcement fines in recent years landed on non-US firms.

Two more of his asides are worth passing on. He begged people never to use the word whistleblower, which in the Netherlands, he said, lands you with a second-hand caravan, no job and no friends outside the village; even the national House for Whistleblowers has suggested dropping it. Call it speak up, or sharing your concerns, and make it easy, because tips from employees uncover far more wrongdoing than internal audit does. And on method: forget the annual two-hour block that sales will quietly fake. Two or three minutes a month, varied per person so nobody can copy answers into the chat, and made personal, in the spirit of a Coca-Cola training film he admires that spells out what losing your job, your house and your savings actually looks like for your family.

The real enemy is naivety

For all the cases and numbers, Notermans kept returning to a gentle point. The people who cause these problems are usually not villains; they are decent colleagues who believe they are helping the company, or who simply do not know where the line is. That is why he is optimistic. You cannot train away greed, but you can train away ignorance, and most of this is ignorance. Entrepreneurship, he said, does not exist at zero percent risk; it is the creating, taking and managing of risk. The job is not to say no to everything, but to make sure that when the milk is rotting in the port, people ask the right questions before they reach for the cash.

He closed with what is coming, a new EU Anti-Corruption Directive on its way into national law, and a new duty for listed Dutch companies to attest not just that staff did the e-learning but that it actually works, which he expects to spread. And he made the offer that said as much about him as the hour did: call me next week, for free, in confidence,

because my reputation matters more to me than sending you an invoice.

The Week of Integrity continues all week, with partner events across the country and online, the seminar on 29 October, the closing event, and a spotlight on International Anti-Corruption Day on 9 December.