Litvack, Karina, Tiffany Butterfield, Harriet Fletcher. "The Governance of Bribery and Corruption." ISIS Asset Management (London), February 2002.

ISIS Asset management surveyed 82 European companies in which it held shares to "evaluate the quality of their management of corruption-related risks." 2/3 of the companies contacted responded to the survey. Key findings:

- 58% of respondents acknowledged that corruption posed a "material risk" to their company.
- 87% had formal written policies or codes of conduct combating corruption.
- Responsibility for enforcement varied: it resided with the Management Committee at 20% of the respondents, the Board at 11%, a combination of the two at 11%, and others at 42%.
- Anti-corruption measures in place included internal audit (85% of respondents), staff training (64%), performance audit (36%), and remuneration (15%).
- 49% of respondents had a whistleblower protection policy.

No tests for statistical significance. Includes excellent concluding commentary on the problems associated with operating in corrupt environments.