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Recent years have seen the flourishing of laws and regulations requiring or encouraging the adoption of corporate compliance programmes, generally under national legal regimes and increasingly, as a condition for participating in public procurement markets. Companies invest considerable effort in putting compliance programmes in place and ensuring that they are effective. Such companies often express scepticism as to the added benefit other anti-corruption efforts, such as Integrity Pacts, can bring. This paper seeks to explore whether, as argued, the Integrity Pact approach duplicates corporate compliance programmes, or, is complementary of them. Drawing on experiences emerging from a pilot project underway in eleven countries in the European Union, the paper concludes that Integrity Pacts can bring a range of benefits that complement compliance programmes and can help address common gaps including supporting in managing risks, delivering training and demonstrating appropriate tone from the top. On this basis it recommends that firms should take a broader view of Integrity Pacts when assessing whether to integrate them into their compliance efforts.  Keywords: Civil society; Anti-corruption; ESIF.

Integrity Pacts and Corporate Compliance Programmes: Contrary or Complementary? Emerging Evidence from a Pilot Project in the EU