Strengthening integrity compliance across DFI investments
GoodBlog | read time: 5 min
Published: 3 March 2026
Development finance institutions (DFIs) operate in some of the world’s most complex and sensitive markets. Working in politically sensitive regions and sectors with significant financial and development stakes, they face a dual mandate: mobilise and deploy private capital responsibly while delivering tangible social, environmental and economic outcomes. Weak governance, corruption risks and often limited local administrative capacity can make it challenging for DFIs and their investees to ensure that integrity and sustainability commitments are implemented effectively in practice and not just on paper.
For over a decade, GoodCorporation has supported DFIs and multilateral development banks (MDBs) to strengthen integrity compliance frameworks, identify and address misconduct risks and build credible, investable institutions across diverse sectors and geographies. This work spans both public and private sectors, covering financial services, electricity distribution, oil and gas, property development, state-owned enterprises in the energy sector, municipalities, pharmaceuticals and renewable energy. Many of these sectors are politically sensitive and exposed to heightened risks of bribery and corruption, fraud, collusion and coercive practices.
In these high-risk sectors, GoodCorporation helps organisations strengthen governance systems, design and embed practical integrity controls and build the operational capability to ensure that risks of misconduct are effectively identified, addressed and managed. In doing so, DFIs can safeguard capital, maintain investor confidence and ensure that projects deliver the intended social, environmental and development outcomes.
The GoodCorporation approach
GoodCorporation’s work in this field draws on our Integrity Compliance Framework, a practical tool used to assess and strengthen the robustness of the management practices in place that relate to risks of fraud, corruption, collusion and coercive practices.
Legislative and regulatory review
Each engagement begins with a thorough review of the local legislative and regulatory environment. Based on this review, and an initial engagement with the client to understand their operations and gain an insight of their current risk landscape, we tailor our integrity compliance framework accordingly to ensure its relevance.Risk assessment and gap analysis
We then conduct detailed on-the-ground risk assessments and gap analyses to understand how policies and controls work in practice. This process includes:
- Reviewing existing policies and procedures as well as records
- Conducting in-person interviews with senior management and process owners
- Engaging directly with employees to understand how risks are identified and managed in day-to-day operations
Where relevant, we draw on our extensive network of local consultants who support our on-site work, ensuring language and cultural nuances are taken into account.
Report and risk register
Following the assessment phase, we develop a report setting out key findings and recommendations. Findings are also put into a risk register which captures key risk categories, risk scenarios, and contributing factors and existing controls, along with the likelihood and impact assessments. The register also includes residual risk ratings, priorities with assigned owners to help ensure accountability, recommended mitigation measures and timelines to guide targeted action.
Anti-Corruption Action Plan (ACAP)
Findings and recommendations from the assessment are then distilled into a structured action plan, which clearly defines recommended activities, timelines and resources implications required to embed the agreed mitigation measures identified during the risk assessment and gap analysis process. This action plan serves as a practical roadmap, enabling organisations to strengthen integrity systems while embedding accountability across all levels of management.
Policy development and roll-out
Where gaps are identified, GoodCorporation drafts tailored policies and procedure documents that reflect the organisation’s operational realities and appropriately address the risks faced, as identified in the risk assessment. Documents frequently developed as a part of this phase include:
- Anti-bribery and corruption (ABC) policies, including guidance on gifts and hospitality and conflicts of interest
- Third-party due diligence procedures
- Whistleblowing policies and procedures
- Codes of conduct
Policies are drafted in English and then translated into the relevant local language with the support of GoodCorporation’s local consultants to ensure that cultural and business nuances are taken into account.
GoodCorporation also drafts job descriptions and supports the recruitment process for compliance roles, helping organisations establish appropriately qualified personnel to oversee the implementation and sustainable growth of the integrity framework moving forward.
Capacity building
Policies alone are insufficient to drive lasting change. GoodCorporation develops customised training materials and delivers organisation-wide training programmes. High-risk functions, including procurement and finance, as well as senior leadership, receive targeted sessions to reinforce understanding and accountability.
Ongoing training, combined with periodic feedback sessions, fosters a culture of integrity and ensures that compliance becomes embedded in everyday decision-making.
Case study
GoodCorporation was engaged by a DFI to develop an ACAP. The work began in a challenging environment with no meaningful ABC framework in operation, weak legislative underpinnings and initially limited engagement from the counterpart institution. Although documentation suggested that an ABC programme and Compliance Officer were already in place, on-site assessment showed that neither existed in practice. Nonetheless, the written framework broadly aligned with national legislative requirements and provided a useful basis on which GoodCorporation could build.
Using a structured, three-phase approach, comprising a review of the national anti-corruption landscape; on-site gap analysis and risk assessment, and the creation of tailored policy templates and training, GoodCorporation worked with senior leadership to develop a credible and operational ACAP. Engagement strengthened as the project progressed, supported by increased involvement from local representatives of the DFI and the appointment of a senior official to oversee implementation.
Despite this progress, embedding a sustainable integrity culture remained challenging. Legislative gaps, hierarchical structures and post-Soviet cultural norms, particularly around whistleblowing and the registration of gifts, continued to act as barriers. Within the project scope, however, the recommendations were effectively implemented, laying foundations for long-term improvements provided that the recommended oversight, communication, training and monitoring continue.
Key success factors
Experience across sectors and geographies has highlighted several critical factors for successful integrity programme implementation:
• Senior-level sponsorship: A designated senior contact with explicit endorsement from top management ensures organisational engagement and demonstrates a genuine commitment to integrity
• Institutional ownership: Active participation from key stakeholders enables smoother implementation and reinforces accountability
• Continuous reinforcement: Ongoing training ensures policies influence behaviour and are integrated into operational practice
• Regular review and feedback: Periodic sessions allow organisations to identify emerging risks, reassess gaps in controls, and maintain momentum
Outcomes and impact
Through this structured, practical approach, GoodCorporation has helped DFIs and their investees:
• Strengthen governance and internal controls
• Enhance risk visibility and management
• Build capable, independent compliance functions
• Demonstrate credible integrity performance to investors
These improvements have helped investees attract and deploy capital responsibly, while DFIs can better ensure that investments deliver genuine development impact.
Building credible, investable institutions
In high-risk markets, credibility is currency. Financial discipline, operational transparency and strong governance are essential for mobilising capital sustainably. GoodCorporation’s work ensures that DFIs and their investees are not only compliant on paper but equipped to manage integrity risks in practice, delivering long-term, measurable impact.
By embedding integrity into the core of organisational culture and operations, GoodCorporation enables DFIs to bridge the gap between intention and action, turning compliance into a driver of trust, investment, and sustainable development.
